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 (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. 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 and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.

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

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

FEMA Form 008-0-15

Form Title:

Community Preparedness and Participation Survey

Component:

Federal Emergency
Management Agency
(FEMA)

Office:

Protection and National
Preparedness (PNP)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Community Preparedness and Participation Survey
OMB Control
Number:
Collection status:

1660-0105
Extension

OMB Expiration
Date:
Date of last PTA (if
applicable):

September 30, 2017
September 16,
2013

Name:
Office:

PROJECT OR PROGRAM MANAGER
Jacqueline Snelling
Individual and Community Title:
Senior Advisor
Preparedness Division

Phone:

202 786-9577

Email:

[email protected]
.gov

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

Name:
Office:
Phone:

Sherina Greene
Record Management
202-646-4343

Title:
Email:

Management Analyst
[email protected]
ov
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
This PTA is being submitted for the renewal of FEMA’s use of Community Preparedness and
Participation Survey (FEMA Form 008-0-15) per the three year expiration. FEMA is now
collecting information related to caregiver status but is no longer collecting information
related to job status. The changes are reflected in this PTA.
The Individual and Community Preparedness Division (ICPD) works to strengthen the
Nation’s resilience by preparing individuals, organizations, and communities for any disaster
or emergency. To execute its mission, ICPD conducts research to better understand effective
preparedness actions and ways to motivate the public to take those actions. ICPD also
develops and shares preparedness resources based upon its research.
ICPD analyzes and uses data collected in FEMA Form 008-0-15, Community Preparedness
and Participation Survey, to identify progress and gaps in individual and community
preparedness and participation and to better understand the motivators and barriers to
preparedness in general and about specific hazards (e.g., hurricanes, floods, wildfires). The
survey measures the public’s knowledge, attitudes, and behaviors relative to preparing for a
range of hazards.
The Community Preparedness and Participation Survey does not collect personally identifiable
information (PII) from the public. ICPD has hired a contractor to conduct the surveys. The
contractor uses its existing phone directory system to create a pool of phone numbers that will
be used to conduct the anonymous survey. FEMA does not receive any of the phone numbers
but does retain the survey responses and any data analysis for the purposes stated above.

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

b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
The Stafford Act, Title VI, Emergency Preparedness (42 U.S.C. 5195-5195(a)) identifies the
purpose of emergency preparedness “for the protection of life and property in the United
States from hazards.” It directs that the Federal Government “provide necessary direction,
coordination, and guidance” as authorized for a comprehensive emergency preparedness
system for all hazards. Emergency preparedness is defined as all “activities and measures
designed or undertaken to prepare or minimize the effects of a hazard upon the civilian
population….” The “conduct of research” is among the measures to be undertaken in
preparation for hazards.
The DHS Strategic Plan 2014-2018 includes a Goal 5.1 including the goal for “improving
strategies for the mission of empowering individuals and communities to strengthen and
sustain their own preparedness”1
The FEMA Strategic Plan 2014-2018 references FEMA priorities for preparing individuals in
Priority #1- to achieve a survivor-centric mission where “Individuals and communities know
the steps to take, have the tools required, and take appropriate actions, before, during, and after
disasters, and in Priority #3, to better prepare survivors and bystanders.2
Presidential Policy Directive-8 (PPD-8) directs the Secretary of Homeland Security to
“coordinate a comprehensive campaign to build and sustain national preparedness, including
public outreach and community-based and private sector programs to enhance national
resilience, the provision of Federal financial assistance, preparedness efforts by the Federal
Government, and national research and development efforts.”

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII3)?

☐ Yes
☒ No

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.

1
2
3

Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which 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.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.
c. Who will complete and
submit this form? (Check
all that apply.)

☐ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
This is a survey given over the telephone. FEMA
contracts with a Research Company to conduct
the surveys and compile the collected data.

d. How do individuals
complete the form? Check
all that apply.

☒ Paper.
☒ Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
The Community Preparedness and Participation Survey collects demographic and
contextual characteristics as the relate to preparedness, including:
- Prior experience with disasters;
- Health condition;
- Caregiver;
- Community Engagement;
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

-

Gender;
Age;
Children under 18 in household;
Race and Ethnicity;
Household Income category;
Geography and Location of Residence; (zip code, state, county); years at location;
Home ownership;
Language;
Education; and
Type of telephone (landline or cell).

No PII data elements are collected.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply. None apply
☐ Social Security number
☐ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
No information is collected containing any SSN or other SPII elements.

h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
No SPII is collected or used.

i.

Are individuals
provided notice at the

Privacy Threshold Analysis – IC/Form

☒ Yes. Please describe how notice is provided.

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

time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

As this is a telephone survey, notice is read to the
respondent by the research company doing the survey
for FEMA as follows: Hello, this is ______ calling for the
Research Company on behalf of the Federal Emergency
Management Agency (FEMA). We are doing a special poll
about preparation for disasters and would like to include
your opinions. This survey will take about 15 minutes
and is completely voluntary.
These questions comply have been approved by the Office
of Management and Budget under number 1660-0105.If
you have any questions about the survey, you can reach a
FEMA contact by calling (1-202 646-2500) and indicating
you want to talk with a contact for the FEMA Survey.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
FEMA Network Storage (R Drive).
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered).
Data is manually entered into forms which are
manually saved to the R drive.
☐ Automatically. Please describe.

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

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

☐ By a unique identifier.4 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
All search would be done by types of disasters or
demographic information like county or state or
zip code of respondents.
ICPD records are destroyed immediately after data
have been entered or otherwise incorporated into the
master file or database and verified, but longer
retention is authorized if required for business use,
per EDP 2-2.
ICPD staff uses the collected data for studies and
development of trend analysis. Records are
continuously used and monitored. When they are no
longer deemed useful for analysis the records will be
destroyed.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?

☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.
☒ No. Information on this form is not shared outside of the collecting office.

4

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which 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.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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

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

Christopher Rogers

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

May 12, 2017

Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

Click here to enter a date.
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
The form does not collect PII.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
FEMA Privacy recommends that this collection be adjudicated as non-privacy
sensitive.

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

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Hannah Burgess

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1144881
June 13, 2017
June 13, 2020

DESIGNATION
Privacy Sensitive IC or
Form:

Choose an item. If “no” PTA adjudication is complete.

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 SPII
applies.
☐ Privacy Act Statement required.
☐ Privacy Impact Assessment (PIA) required.
☐ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

DHS IC/Forms Review:

DHS PRIV has not received this ICR/Form.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
e(3) statement not required.
Statement:
Click here to enter text.
PTA:
No system PTA required.
Click here to enter text.
PIA:
Choose an item.
If covered by existing PIA, please list: Click here to enter text.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

If a PIA update is required, please list: Click here to enter text.
SORN:
Choose an item.
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
This PTA is being submitted for the renewal of FEMA’s use of Community
Preparedness and Participation Survey (FEMA Form 008-0-15) per the three year
expiration. The anonymous survey is conducted via telephone, and a contractor uses
its existing phone directory system to create a pool of phone numbers that will be
used to conduct the survey. FEMA does not receive the phone numbers used in the
survey, but does receive the survey responses, which are then used to identify
progress and gaps in individual and community preparedness and participation and
to better understand the motivators and barriers to preparedness in general and
about specific hazards.
The survey collects demographic and contextual information on disaster
preparedness from members of the public including age, gender, income level, and
geography. No PII is collected, and the information that is collected is not enough to
determine an individual’s identity. The DHS Privacy Office agrees with FEMA that the
Community Preparedness and Participation Survey is a non-privacy sensitive
system.
Therefore, a PTA is sufficient and no PIA is necessary. SORN coverage is also not
required, as no PII is collected and no information is retrieved by unique identifier.

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