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:

Effectiveness of a Community’s Implementation of the NFIP Community
Assistance Program CAC and CAV Reports (OMB ICR No. 1660-0023)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Federal Insurance and
Mitigation Administration
(FIMA)

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Operational

Date first
developed:
Date of last PTA
update

1985

Pilot launch
date:

Click here to enter a date.

N/A

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:

Bret Gates

Office:

IM-DM-RR-FM

Title:

Senior Program Specialist

Phone:

202-646-4133

Email:

[email protected]

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 7

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Renewal PTA
FEMA’s completion of this PTA is part of the Office of Management and Budget (OMB) Information
Collection Resource (ICR) review and renewal process. The FEMA FIMA uses FEMA Form (FF) 086-028, Community Assistance Contact (CAC) and FF 086-0-29, Community Assistance Visit (CAV) in
determining community assistance needs. These information collection tools provide a systematic means
of monitoring community NFIP compliance. Through the CAC and CAV process and associated FEMA
forms used to collect the data, FEMA can also determine to what extent communities are achieving the
flood loss reduction objectives of the NFIP. By providing assistance to communities, the CAC and CAV
process also serve to enhance FEMA’s goals of reducing future flood losses, thereby achieving the costcontainment objective of the NFIP. This information is part of OMB ICR No. 1660-0023.

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):
Contractors working on behalf of DHS
Employees of other federal agencies

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

The following information about FEMA employees, local government, and community points of contacts
include:
• name (both full and initials)
• telephone number,
• address,
• name of community,
• community ID number, and
• agency.
No. Please continue to next question.
4(a) Does the project, program, or system
Yes. If yes, please list all personal identifiers
retrieve information by personal identifier?
used: Name.
4(b) Does the project, program, or system
No.
use Social Security Numbers (SSN)?
Yes.
4(c) If yes, please provide the specific legal
Click here to enter text.
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?

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?
3

No.

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 5 of 7

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?

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/agencies who have
requested access to their PII?
9. Is there a FIPS 199 determination? 4

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:

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained: The program uses the FEMA FOIA
process, which uses FOIA Express to account for
disclosures.
Unknown.
No.
Yes. Please indicate the determinations for each
of the following:
Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

High

Undefined

Moderate

Availability:
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 6 of 7

Low

Moderate

High

Undefined

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

LeVar J. Sykes

Date submitted to Component Privacy
Office:

Click here to enter a date.

Date submitted to DHS Privacy Office:

December 15, 2014

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
FEMA Privacy recommends coverage for this collection under the National Flood Insurance Program
Information Technology Systems (NFIP ITS) PIA and the National Flood Insurance Program Files
SORN.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Eric M. Leckey

PCTS Workflow Number:

1057469

Date approved by DHS Privacy Office:

December 17, 2014

PTA Expiration Date

December 17, 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.

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

Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.
Choose an item.
PIA:

SORN:

DHS/FEMA/PIA-011 – National Flood Insurance Program (NFIP) Information Technology
Systems (ITS)
Choose an item.

DHS/FEMA-003 - National Flood Insurance Program Files
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The purpose of this PTA is to review, document the review, and annotate privacy compliance coverage
for the Effectiveness of a Community’s Implementation of the NFIP Community Assistance Program
(OMB ICR No. 1660-0016). This is a privacy sensitive system which collects business-related PII of
government personnel and individuals of the public. FEMA’s collection, maintenance, and use of
information is covered under DHS/FEMA/PIA-011 – National Flood Insurance Program (NFIP)
Information Technology Systems (ITS) PIA and DHS/FEMA-003 - National Flood Insurance Program
Files SORN.