Privacy Threshold Analysis (PTA)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 1 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
This form is used to determine whether
a Privacy Impact Assessment is required.

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under
the E-Government Act of 2002 and the Homeland Security Act of 2002.
Please complete this form and send it to your component Privacy Office. If you do not have a component
Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your component Privacy Office, the DHS Privacy Office will review this form. If a
PIA is required, the DHS Privacy Office will send you a copy of the Official Privacy Impact Assessment
Guide and accompanying Template to complete and return.
A copy of the Guide and Template is available on the DHS Privacy Office website,
www.dhs.gov/privacy, on DHSConnect and directly from the DHS Privacy Office via email:
[email protected], phone: 202-343-1717.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Citizens Corps (CCORPS)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

National Preparedness

Xacta FISMA
Name (if
applicable):

Citizens Corps (CCORPS)

Xacta FISMA
Number (if
applicable):

FEM-06753-MAJ-06753

Type of Project or
Program:

Program

Project or
program
status:

Operational

Date first
developed:
Date of last PTA
update

N/A

Pilot launch
date:

N/A

June 28, 2013

Pilot end date:

N/A

ATO Status (if
applicable)

Complete

ATO
expiration date
(if applicable):

September 23, 2015

PROJECT OR PROGRAM MANAGER
Name:

Samuel Hultzman

Office:

Protection and National
Preparedness

Title:

IT Program Manager

Phone:

202-786-9866

Email:

[email protected]
ov

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

John Shore

Phone:

202-786-9638

Email:

[email protected]
hs.gov

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 3 of 7

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Updated PTA
The Federal Emergency Management Agency (FEMA), Office of Protection and National Preparedness
(PNP), Individual and Community Preparedness Division (ICPD) administer the Citizen Corps Program,
which also includes the Citizen Corps web-based application, and the Citizen Corps Database. Citizen
Corps’ mission is to strengthen the collaboration between government and community leaders from all
sectors to encourage citizens’ preparedness through education, training, and volunteer service to make
communities safer, stronger, and better prepared to respond to all hazards and all threats. Through
Citizen Corps, communities can establish and register Citizen Corps Councils (Councils) and Community
Emergency Response Team (CERT) programs. The Citizen Corps system collects personally identifiable
information (PII) associated with points of contacts (POC) designated by Councils, CERTs, and other
Citizen Corps partners.
This PTA is being updated because the previous adjudication of ‘New PIA Required’ is no longer
accurate. The Citizen Corp PIA was signed June 28, 2013.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology, please stop here and contact the DHS
Privacy Office for further guidance.

Closed Circuit Television (CCTV)
Social Media
Web portal 1 (e.g., SharePoint)
Contact Lists
None of these

3. From whom does the Project or
Program collect, maintain, use, or
disseminate information?
Please check all that apply.

This program does not collect any personally
identifiable information 2
Members of the public
DHS employees/contractors (list components):
FEMA.
Contractors working on behalf of DHS

1

Informational and collaboration-based portals in operation at DHS and its components that collect, use, maintain, and share
limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who
seek to gain access to the portal.
2
DHS defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the
identity of an individual to be directly or indirectly inferred, including any information that is linked or linkable to that individual,
regardless of whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to
the Department. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial
harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 4 of 7

Employees of other federal agencies

4. What specific information about individuals is collected, generated, or retained?
Names, Mailing Addresses, Email Addresses, and Telephone Numbers

4(a) Does the project, program, or system
retrieve information by personal identifier?
4(b) Does the project, program, or system
use Social Security Numbers (SSN)?
4(c) If yes, please provide the specific legal
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
an information technology/system, does it
relate solely to infrastructure?

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used:
No.
Yes.
N/A

N/A

No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?
4(f) If header or payload data 3 is stored in the communication traffic log, please detail the data
elements stored.
N/A

3

When data is sent over the Internet, each unit transmitted includes both header information and the actual data being sent. The
header identifies the source and destination of the packet, while the actual data is referred to as the payload. Because header
information, or overhead data, is only used in the transmission process, it is stripped from the packet when it reaches its
destination. Therefore, the payload is the only data received by the destination system.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 5 of 7

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?

No.
Yes. If yes, please list:
N/A

6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?
6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?

No.
Yes. If yes, please list:
N/A
Choose an item.
Please describe applicable information sharing
governance in place: N/A

No.
Yes. If yes, please list:

No. What steps will be taken to develop and
maintain the accounting:
8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have
requested access to their PII?

4

Yes. In what format is the accounting
maintained:
The FEMA Disclosure Officer who maintains the
accounting of what records are disclosed and to
whom.

PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes. Often, these
systems are listed as “interconnected systems” in Xacta.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 6 of 7

9. Is there a FIPS 199 determination? 4

Unknown.
No.
Yes. Please indicate the determinations for each
of the following:

Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

Moderate

High

Undefined

Availability:
Low
Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Lane Raffray

Date submitted to Component Privacy
Office:

March 30, 2015

Date submitted to DHS Privacy Office:

March 30, 2015

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: DHS/FEMA/PIA-029 - Citizen Corps Program
SORN: DHS/FEMA-006 - Citizen Corps Program July 22, 2013 78 FR 43890
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Eric M. Leckey

PCTS Workflow Number:

1076311

Date approved by DHS Privacy Office:

March 31, 2015

PTA Expiration Date

March 31, 2018

4

FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 7 of 7

DESIGNATION
Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

IT System
If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
New information sharing arrangement is required.
DHS Policy for Computer-Readable Extracts Containing Sensitive PII
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.

PIA:

System covered by existing PIA
If covered by existing PIA, please list: DHS/FEMA/PIA-029 - Citizen Corps Program
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/FEMA-006 - Citizen Corps Program July
22, 2013 78 FR 43890
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The PTA was updated because the previous PTA, adjudicated 12/18/2012, noted that a “New PIA was
required.” The Citizen Corp PIA was signed June 28, 2013. This PTA was updated to reflect that privacy
compliance coverage. No changes were made to the Citizen Corps SORN, DHS/FEMA-006 - Citizen
Corps Program (July 22, 2013, 78 FR 43890). No further action is required at this time.