Privacy Threshold Analysis (PTA)

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 1 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)

CONTACT LISTS
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:
Rebecca J. Richards
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703-235-0780

[email protected]

Upon receipt, 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 DHSOnline and directly from the DHS Privacy Office via email: [email protected], phone: 703-235-0780.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: February 11, 2014
NAME of Project: Office of External Affairs Survey: Additions to Contact Database
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: James McIntyre
Email for Project Manager: [email protected]

Phone number for Project Manger: 202-646-3922
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
Other: Information Collection Request



The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note, for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed
for potential privacy impact.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 7
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Within FEMA's Office of External Affairs, the Disaster Operations Division will be
fielding a survey to collect feedback from organizations serving individuals with
limited English proficiency. The Disaster Operations Division is adding a question to
the survey asking respondents if they would like to receive future correspondance
from FEMA about the services that the Office of External Affairs, Disaster Operations
Division provides. If respondents answer in the affirmative, they will then be
prompted to provide their contact information.
Information will be collected through survey's given to organizations that support
Limited English Proficiency (LEP) populations during a disaster to assess and
improve FEMA's outreach to those populations. These surveys will be filled out
hard-copy by respondents, disseminated and collected by FEMA's Disaster Survivor
Assistance Teams (DSAT) in the field. They will be then turned back into the LEP
team at the Joint Field Office (JFO) who will compile the information and add into
electronic database. The PII information is an optional question at the end of the
survey, if respondents would like to receive future information from FEMA.
This contact information will be stored in a database apart from the survey responses
and used by FEMA to contact the individuals. The organizational information will be
maintained in a database to reach out to those partners in the future with general
preparedness information, and response information when a new disaster occurs in
their area.
The PII would be kept separate and apart from the survey answers that do not
contain PII.

2.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed:
Date last updated:

3.

Is the information collected directly from the individuals seeking information from the
Department or working collaboratively with the Department on various projects?
Yes.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 7
No. Please describe the information source and collection method.

4.

Does the individual have the option to decline submitting the information collected?
Yes.
No.

5.

Is the information collected limited to non-sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.

6.

What information about individuals could be collected, generated or retained?
Information to be collected includes: first and last name, email address, state, county,
name of the organization they represent (if applicable), and phone number
(optional).

7.

Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No.

8.

With whom could the information be shared?
The information will not be shared outside of FEMA.

9.

Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
No.

10.

Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 7
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

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 6 of 7
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: April 2, 2014
NAME of the DHS Privacy Office Reviewer: Jameson Morgan
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System
National Security System
Legacy System
HR System
Rule
Other: Survey
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: DHS/ALL/PIA-006 Department of
Homeland Security General Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL-002 - Department of
Homeland Security (DHS) Mailing and Other Lists System
A new SORN is required.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 7
DHS PRIVACY OFFICE COMMENTS
The DHS Privacy Office approves EA Disaster Operations Survey Contacts as a
privacy sensative system with coverage under the DHS/ALL/PIA - 006 General
Contacts List PIA and the DHS/ALL - 002 Mailing and other Lists SORN.
This survey collects limited PII for the purpose of contacting LEP individuals who
would like future correspondance from FEMA about the services that the Office of
External Affairs, Disaster Operations Division provides.
The information collection is consistent with the DHS/ALL/PIA - 006, which allows
DHS to collect a minimal amount of contact information in order to distribute
information and perform various other administrative tasks. The DHS/ALL - 002
Mailing and Other Lists SORN allows DHS to mail informational literature or
responses to those who request it and for other purposes for which mailing or
contact lists may be created.