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:

008-0-0-24

Form Title:

Youth Preparedness Council (YPC) Application Form

Component:

Federal Emergency
Management Agency
(FEMA)

Office:

Individual and
Community
Preparedness Division

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Individual & Community Preparedness Division (ICPD)

Annual Youth Preparedness Council (YPC) Application
Form
OMB Control
Number:
Collection status:
Name:
Office:

Phone:

1660-NW94

New Collection

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

Click here to enter a
date.
Click here to enter
a date.

PROJECT OR PROGRAM MANAGER
Allison Carlock
Individual and Community Title:
Program Specialist for Youth
Preparedness
Programs
202-786-9781
Email:
[email protected]
v

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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:

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Millicent Brown
Records Management
Title:
Information Collection
Division
Analyst
202-646-2814
Email:
[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.
The Federal Emergency Management Agency (FEMA) conducts this new Privacy Threshold
Analysis (PTA) as part of the Office of Management and Budget (OMB) Information Collection
Resources (ICR) approval process. This PTA is part of OMB ICR 1660-NW94.
The FEMA Youth Preparedness Council (YPC) vision is to bring together youth leaders from
across the country who are highly interested and engaged in advocating youth disaster
preparedness and making a difference in their communities.
Members are expected to represent the youth perspective on emergency preparedness and take
information back to their communities to share. Each Council member is expected to develop and
complete one preparedness-related project specific to his/her region and interests. There is no
minimum or maximum age requirement for YPC applicants but they must be at least in the 8th
grade and not beyond 11th grade when they apply.
Youth apply using personal identifiable information (PII) such as a youth’s demographic, contact
information, along with information related to extracurricular activities and academic standing.
FEMA Form 008-0-0-24 collects and retains, confidentially, the applicants PII for the purposes of
providing acceptance/denial responses to applicants and determining a representative sample of
applicants. Letters of recommendation are required, while supplemental materials highlighting
past achievements are encouraged. Applicants are required to provide the name and contact
telephone number of their parent(s) or guardian(s) as well as letters of recommendation that
include the name and relationship of the individual providing the recommendation.

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

Applicants have the option to use video to record their responses to the application and submit the
video as their application to the YPC.

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.
This collection meets the requirements of 6 U.S.C. §742, “National Preparedness”, and
Presidential Policy Directive – 8 (PPD-8) which emphasize the need for involvement from all
sectors of society in preparing for and responding to threats and hazards. The information
collected from successful and non-successful applicants will be maintained per applicable
retention schedules.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

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

c. Who will complete and
submit this form? (Check
all that apply.)

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☐ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

☒ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.

1
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

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

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.
If applicant is under 18 years of age, a parent or
guardian may need to provide a name, phone
number and/or email, and signature. FEMA also
collects the names of individuals recommending a
youth as part of the application for YPC
membership.

☒ 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.
FEMA collects the following information from youth applying for membership to the FEMA
Youth Preparedness Council:
Name;
Date of Birth;
Age;
Street Address, City, State, Zip/Postal Code;
Race/ethnicity;
Gender/sex;
Account number;
Email address;
Telephone number;
Education grade level;
Academic records and extracurricular activities; and
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Disaster preparedness/response experience (narrative format).
FEMA collects the following information from the youth applicants parent or guardian:
Name;
Telephone number;
Email Address
FEMA collect the following information from individuals recommending a youth as part of the
application for YPC membership:
Name,
Relationship to applicant,
Narrative about the applicant
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. No, SSNs or other Sensitive PII elements are not collected.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:

g. List the specific authority to collect SSN or these other SPII elements.
N/A because SSN and SPII are not collected.

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.
N/A
i.

Are individuals
provided notice at the
time of collection by

Privacy Threshold Analysis – IC/Form

☒ Yes. Please describe how notice is provided.
An e(3) Privacy Act Statement will be provided.
☐ No.
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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 (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

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

b. If electronic, how
does DHS input the
responses into the IT
system?
c. How would a user
search the
information
submitted on the
forms, i.e., how is the

store the data from the form.
Data is stored on an internal FEMA Sharepoint site
which is secured from public access and only users
involved have access.
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Currently, FEMA YPC files are stored on the
Preparedness Directorate Shared Drive in the Youth
Preparedness Council folder.
☒ Manually (data elements manually entered). Please
describe.
If applicants do not submit through online process, FEMA
ICPD staff will manually input or scan the information.
☐ Automatically. Please describe.
Click here to enter text.
☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
By an account number
☐ By a non-personal identifier. Please describe.
Click here to enter text.

2
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

information
retrieved?
d. What is the records
Records Schedule Identifier: ADM 4-3: Routine
retention
Program Correspondence. These are temporary files
schedule(s)? Include
that will be destroyed when two years old or sooner,
if purpose has been served.
the records schedule
number.
e. How do you ensure
FEMA IT System Administrators will delete
that records are
information in accordance with FEMA Records
disposed of or deleted
Schedule.
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.

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:

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

Christopher Rogers
August 31, 2015
Click here to enter a date.

☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

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 interim PIA coverage under DHS/FEMA/PIA-029 – Citizen
Corps Program and interim SORN coverage under DHS/ALL-011 – Department of
Homeland Security Biographies and Awards, as the collection is already occurring. FEMA
Privacy will work with the program area to develop a Youth Preparedness Council PIA.
After the PIA development, we will begin work on a SORN.

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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:

Emily Stoner

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

1138493
March 23, 2017
March 23, 2018

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

DHS PRIV has not received this ICR/Form.

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.

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 update is required.
Statement:
PTA:
No system PTA required.
Click here to enter text.
PIA:
PIA update is required.
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: DHS/FEMA/PIA-029 Citizen
Corps Program
SORN:
SORN update is required.
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: DHS/FEMA-006 Citizen Corps
Program, 78 FR 43890 (July 22, 2013)
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.

DHS Privacy Office finds that FORM 1660-NW94 (Youth Preparedness Council (YPC))
is a privacy-sensitive collection, requiring both PIA and SORN coverage. The form
collects sensitive Personally Identifiable Information (PII), including name, date of
birth, age, home address, race/ethnicity, gender/sex, account number, email
address, telephone number, education grade level, academic records and
extracurricular activities, relationship to applicant, narrative about the applicant,
and disaster preparedness/response experience from members of the public.
Information collected in this form is used by FEMA for the purpose of providing
acceptance/denial responses to applicants and determining a representative sample
of applicants.
DHS Privacy Office agrees with FEMA’s recommendation of interim PIA coverage
under DHS/FEMA/PIA-029 Citizen Corps Program, which outlines FEMA’s collection,
use, maintenance, retrieval, and dissemination of PII associated with points of
contacts designated by Councils, CERTs, and other Citizen Corps partners. DHS
Privacy Office disagrees with FEMA’s recommendation of interim SORN coverage
under DHS/ALL-011 Department of Homeland Security Biographies and Awards, 73
FR 66654 (November 10, 2008). Instead DHS Privacy Office finds that better interim
SORN coverage is provided under DHS/ALL-003 Department of Homeland Security
General Training Records, 73 FR 71656 (November 25, 2008), which describes the
Department’s collection and documentation of individuals who are provided DHS
training, and DHS/FEMA-006 Citizen Corps Program, 78 FR 43890 (July 22, 2013),
which describes the Department’s establishment and registration of Citizen Corps
Councils and CERT programs.
The YPC is a similar program to the Citizen Corps Program. Therefore, DHS Privacy
Office recommends updating the DHS/FEMA/PIA-029 and the DHS/FEMA-006 to
incorporate the YPC program and provide adequate coverage for the information
being collected from this form (unique identifier, age, gender, race/ethnicity,
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

academic records, etc.) and the categories of individuals from which the form is
collecting information (youth applicants, parent/guardian of applicant, and
individuals submitting recommendations for applicant).
The Privacy Act Statement associated with this form has been updated to reflect the
interim SORN coverage. The Privacy Act Statement also must be included on the
application form. Once DHS/FEMA-006 has been updated, the Privacy Act Statement
will need to be updated to reflect the new SORN coverage.
This PTA expires in 1 year.

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