PTA for Principal Advisory Report

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:
Form Title:

Form Number(s): FEMA Form 078-0-2
Principal Advisor’s Report

Component:

Federal Emergency
Management Agency
(FEMA)

Collection Title:
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:

Phone:

Office:

Office of Response and
Recovery

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Fire Management Assistance Grant Program
1660 - 0058
OMB Expiration
Date:
Extension
Date of last PTA (if
applicable):

January 31, 2018
July 2, 2014

PROJECT OR PROGRAM MANAGER
Allen Wineland
Public Assistance Division
Title:
FMAG Program Manager
202-702-1472
Email:
[email protected]

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Millicent Brown
Records Management Branch, Title:
Sr. Forms Management &
Information Management
Information Collections
Division
Analyst
(202) 212-7014
Email:
[email protected]

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

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 form provides a third party assessment of a wildland fire by a professional fire fighter
(Principal Advisor) who has no vested interest in the outcome of a potential Fire Management
Assistance Grant (FMAG) declaration. This form is completed by a U.S. Forest Service or Bureau of
Land management professional fire fighter/Principal Advisor, and it collects his or her name,
signature, the federal agency the Principal Advisor works for, office location, and up to three phone
numbers (day (work), night (personal), and/or cellular (personal/work)).
The form captures information related to the fire incident to ensure the accuracy, completeness, and
factual nature regarding the threat posed by an uncontrolled wildland fire for which a State is
requesting a FMAG declaration. The form includes information on whether or not there are other
fires nearby that may result in a conflagration and the number of large fires currently burning in the
state. Information is also provided regarding the prevailing weather conditions including current
temperature, humidity, wind and the proximity of fire to homes and communities and any natural or
other barriers between fire and communities.
The name of any nationally recognized indices that predict the potential severity of a fire is included
and the probability of growth and potential danger of the fire based on the geography, vegetation,
and prevailing weather conditions.
Finally, the form has a place for an overall assessment of the fire that sums up the threat the fire
poses to people, communities, infrastructure, and the environment.
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 Federal Emergency Management Agency working through its 10 regions under the provisions
of Section 420 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C 5187,
as amended by § 303 of the Disaster Mitigation Act of 2000, uses these forms to collection
information needed to make fire severity declaration and grant eligibility decisions for States, local
governments and tribal governments. The authority to collect this information is include by
reference.

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

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?
b. From which type(s) of
individuals does this form
collect information? (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.

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.
States, local governments and tribal governments.

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.
 Name of the Principal Advisor
 Agency;
 Office location;
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



f.

Phone numbers (day (work), night (personal), cellular (personal/work)); and
Signature.
Does this form collect Social Security number (SSN) or other element that is stand-alone
Sensitive Personally Identifiable Information (SPII)? Check all that apply.

☐ Social Security number
☐ Tax Identification Number

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID

☐ Visa Number

☐ Known Traveler Number

☐ Passport Number

☐ Trusted Traveler Number (Global Entry,
Pre-Check, etc.)
☐ Driver’s License Number

☐ Alien Number (A-Number)

☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
N/A
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
☒ Yes. Please describe how notice is provided.
provided notice at the
A Privacy Notice is included on the form.
time of collection by
☐ No.
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 the
☒ Paper. Please describe.
original, completed
Click here to enter text.
IC/forms?
☒ Electronic. Please describe the IT system that will store
the data from the form.
The forms are stored electronically in FEMA’s grant
management system database (EMMIE) and paper copies are
stored in file cabinets at regional and Headquarters Offices.

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

☐ Scanned forms (completed forms are scanned into an
electronic repository). Please describe the electronic
repository.
b. If electronic, how does
DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
Selected data is captured via keyboard entry from a
paper copy of the form. Data elements that may be
provided include the name, address, and mobile and
desk telephone numbers (day and night) of the
requesting official on behalf of the agency they
represent.
☐ Automatically. Please describe.
Click here to enter text.

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

☐ By a unique identifier.2 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.
The information is accessed in EMMIE by FMAG
declaration number and/or a specific Project
Worksheet associated with an FMAG declaration.
DAP 4-2-1: TEMPORARY. Cut off when termination
memorandum is approved. Retire to FRC 1 year after
cutoff. Destroy 6 years 3 months after cutoff.

d. What is the records
retention schedule(s)?
Include the records
schedule number.
e. How do you ensure that
Managers and staff at each regional office and HQ office
records are disposed of
have the primary responsibility to ensure records are
or deleted in
disposed, deleted, and preserved in accordance with DAP
accordance with the
4-2-1.
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.
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

☐ 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:

Heather K. Mills

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

July 27, 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.)

August 16, 2017
☒ 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.
PIA Coverage:
 DHS/FEMA/PIA – 013 Grant Management Programs (February 19, 2015).

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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

1148983
September 6, 2017
September 6, 2020

DESIGNATION
Privacy Sensitive IC or
Form:

Yes 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 commented on this ICR/Form.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: FEMA Form 078-0-2
Privacy Act
New e(3) statement is required.
Statement:
Privacy Notice Form 1660-058 FF 078-0-2
PTA:
New system PTA required.
Click here to enter text.
PIA:
System covered by existing PIA
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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 covered by existing PIA, please list: DHS/FEMA/PIA – 013 Grant
Management Programs
If a PIA update is required, please list: Click here to enter text.
SORN:
If covered by existing SORN, please list:
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.
FEMA Form 078-0-2 is a third party assessment of a wildland fire by a professional fire
fighter (Principal Advisor). The form captures information related to the fire incident to
ensure the accuracy, completeness, and factual nature regarding the threat posed by an
uncontrolled wildland fire for which a State is requesting a FMAG declaration. The form is
completed by a U.S. Forest Service or Bureau of Land management professional fire
fighter/Principal Advisor, and it collects his or her name, signature, the federal agency the
Principal Advisor works for, office location, and up to three phone numbers (day (work),
night (personal), and/or cellular (personal/work)).
The Privacy Office finds that the form is privacy sensitive and a PIA is required because
FEMA collects information from federal employees or contractors, specifically professional
fire fighters. PIA coverage is provided by DHS/FEMA/PIA – 013 Grant Management
Program, which details FEMA’s collection of PII as part of the grant application process.
The DHS Privacy Office also agrees that no SORN is required, since information is not
retrieved by personal identifier. A Privacy Notice, however, is required because the form
collects PII from federal employees or contractors. The Privacy Notice submitted along
with this form needs to be updated to accurately reflect the individual completing the form.

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