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 8

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 8

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

Assistance to Firefighter Grants Program (AFG) (OMB 1660-0054)

Component:

Federal Emergency
Management Agency (FEMA)

Xacta FISMA
Name (if
applicable):

AFG-Assisted Firefighters Grant

Office or
Program:

Assistance to Firefighters
Grant Programs (AFGP)

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Existing

Date first
developed:
Date of last PTA
update

March 29, 2001

Pilot launch
date:

March 2, 2002

December 9, 2011

Pilot end date:

Click here to enter a date.

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Catherine Patterson

Office:

Grants Program Directorate

Title:

Branch Chief

Phone:

202-786-9796

Email:

[email protected].
gov

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

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

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 8

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Renewal PTA
The Assistance to Firefighters Grant (AFG) Program project is a competitive grant opportunity that is
administered by the Assistance to Firefighters Program Office. The grant application package is included
in the Office of Management and Budget (OMB) Information Collection Request (ICR) 1660-0054. The
purpose of the collection is to assess the needs of each individual applicant compared to the other
applicants interested in the opportunity.
The authority for Assistance to Firefighters Grant Program (AFG) is derived from the Federal Fire
Protection and Control Act of 1974 (15 U.S.C. §§ 2229 et seq.), as amended. This submission is
necessary in order for DHS to effectively implement a competitive grant program and meet the fiscal
deadlines. The data generated through the grant application process is stored and maintained in the AFGAssisted Firefighter Grant IT system, which was de-coupled from the National Emergency Management
Information System (NEMIS). This system does not relate to any other grant application system such as
Non‐Disaster (ND) Grants. Applicants are state, county, and municipal organizations/entities in charge of
administering firefighting duties.
The type of information gathered in this collection includes basic contact information for a primary and
two alternate contacts, organization information, the organization’s response area demographics, and a
summary of the organization’s needs with justification. Additionally, grant applicants submit the
following information: First Name, Last Name, Title, Work Phone Number, Home Phone Number,
Mobile Phone Number, Email Address, Organization’s Employee Identification Number (EIN), Banking
Account, and Routing Number.
There have been no changes to the collection since the last version of the PTA. This PTA is being
renewed because ICR 1660-0054 has been decoupled from the AFG Systems PTA.

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
1

This program does not collect any personally
identifiable information 2

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,

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 8

disseminate information?
Please check all that apply.

Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

First Name
Last Name
Middle Initial
Title
Work Phone
Home Phone
Mobile Number
Fax Number
Email Address
Home Address
Organization Name
Mailing Address
Employee Identification Number (EIN)
Banking Account Number
Routing Number
Data Universal Numbering System (DUNS) Number

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

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used:
No.
Yes.
Click here to enter text.

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 5 of 8

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?

Click here to enter text.

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.
Click here to enter text.

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:
Click here to enter text.

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?
3

No.
Yes. If yes, please list:
Click here to enter text.
Choose an item.
Please describe applicable information sharing
governance in place:

No.
Yes. If yes, please list:

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.
4
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 8

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?
9. Is there a FIPS 199 determination? 4

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained:
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:

Tannaz Haddadi

Date submitted to Component Privacy
Office:

September 15, 2014

Date submitted to DHS Privacy Office:

October 2, 2014

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
There have been no changes to the collection since the last version of the PTA. This PTA is being
renewed because ICR 1660-0054 has been decoupled from the AFG Systems PTA. FEMA Privacy
recommends this ICR continue to be covered under DHS/FEMA/PIA-013 Grants Management Program
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 8

and DHS/FEMA-004 Grants Management Information Files SORN since it contains sensitive personal
and financial information.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Eric M. Leckey

PCTS Workflow Number:

1045544

Date approved by DHS Privacy Office:

October 3, 2014

PTA Expiration Date

October 3, 2017
DESIGNATION

Privacy Sensitive System:

Yes

Category of System:

Form/Information Collection

Determination:

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:

DHS/FEMA/PIA-013 Grants Management Program

SORN:

DHS/FEMA-004 Grants Management Information Files

DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
This ICR collects personal and financial PII from grant applicants under the Assistance to Firefighters
Grant program for the purpose of grant evaluation and award.
This PTA was submitted as a 3 year renewal PTA and because the ICR was de-coupled from the AFG
System PTA. As a result, a review of the program has been performed and it was determined that there
were no changes since the last PTA was adjudicated.

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 8 of 8

This ICR should continue to be covered under DHS/FEMA/PIA-013 Grants Management Program and
DHS/FEMA-004 Grants Management Information Files SORN. No further updates are required at this
time.