DHS PRIVACY OFFICE

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U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT





PRIVACY THRESHOLD ANALYSIS (PTA)

Choice Neighborhoods Information Collection 

Office of Public Housing Investments PIH

Instruction & Template




January 31, 2018


PRIVACY THRESHOLD ANALYSIS (PTA)

The PTA is a compliance form developed by the Privacy Branch to identify the use of Personally Identifiable Information (PII) across the Department.  The PTA is the first step in the PII verification process, which focuses on these areas of inquiry: 
    • Purpose for the information,
    • Type of information,
    • Sensitivity of the information,
    • Use of the information,
    • And the risk to the information.
Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under the E-Government Act of 2002 or a System of Record Notice (SORN) is required under the Privacy Act of 1974, as amended.
Please complete this form and send it to your program Privacy Liaison Officer (PLO).  If you have no program Privacy Liaison Officer, please send the PTA to the HUD Privacy Branch:

Marcus Smallwood, Acting, Chief Privacy Officer
Privacy Branch
U.S. Department of Housing and Urban Development

[email protected]

Upon receipt from your program PLO, the HUD Privacy Branch will review this form.  If a PIA or SORN is required, the HUD Privacy Branch will send you a copy of the PIA and SORN templates to complete and return.
PRIVACY THRESHOLD ANALYSIS (PTA)

Summary Information
Project or Program Name:
Choice Neighborhoods Information Collection
Program:
Choice Neighborhoods 
CSAM Name (if applicable):
Click here to enter text.
CSAM Number (if applicable):
Click here to enter text.
Type of Project or Program:
Grant program
Project or program status:
On-going program
Date first developed:
Program started FY10
Pilot launch date:
Click here to enter a date.
Date of last PTA update:
March 1, 2015
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:
Leigh van Rij
Office:
Office of Public Housing Investments, PIH
Title:
Public Housing Revitalization Specialist
Phone:
202-402-5788
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.



Specific PTA Questions
1.   Reason for submitting the PTA:  Choose an item.
Please provide a general description of the project and its purpose so a non-technical person could understand. If this is an updated PTA, please describe what changes and/or upgrades triggering the update to this PTA.  If this is a renewal please state whether there were any changes to the project, program, or system since the last version.

This PTA is needed for the renewal of the Choice Neighborhoods (CN) information collection approval (PRA).  A IPA (Initial Privacy Assessment) was completed previously (March 2015) for the program with the last PRA process.  There have been no changes to the program since that prior IPA was done.

The Choice Neighborhoods grant program began in FY2010.  It supports locally driven strategies to address struggling neighborhoods with distressed public or HUD-assisted housing through a comprehensive approach to neighborhood transformation. Local leaders, residents, and stakeholders, such as public housing authorities, cities, schools, police, business owners, nonprofits, and private developers, come together to create and implement a plan that transforms distressed HUD housing and addresses the challenges in the surrounding neighborhood. The program is designed to catalyze critical improvements in neighborhood assets, including vacant property, housing, services and schools.

Applicants and grantees include local governments, tribal entities, public housing agencies, nonprofits, and for-profit developers that apply jointly with a public entity (i.e., not individuals).

This information collection (PRA) renewal covers a variety of purposes related to the CN program. The information is required to allow HUD to conduct competitions to award and obligate Choice Neighborhood grant funds in accordance with the appropriations act and to manage/report on the grants that are awarded.
For applications, Grants.gov is used.  For other program-related information collections, email and attachments are used as well as an on-line reporting system.


    2. Does this system employ the following technologies?
If you are using these technologies and want coverage under the respective PIA for that technology, please stop here and contact the HUD Privacy Branch for further guidance.

  Social Media
  Web portal2 (e.g., SharePoint)
  Contact Lists
  Public website (e.g. A website operated by HUD, contractor, or other organization on behalf of the HUD
  None of these

    3. From whom does the Project or Program collect, maintain, use, or disseminate information?
       Please check all that apply.
  This program collects no personally identifiable information3
  Members of the public
  HUD employees/contractors (list programs):
  Contractors working on behalf of HUD
  Employees of other federal agencies
  Other (e.g. business entity)
For CN – Other = applicants/grantees


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


Please provide a specific description of information collected, generated, or retained (such as full names, maiden name, mother’s maiden name, alias, social security number, passport number, driver’s license number, taxpayer identification number, patient identification number, financial account, credit card number, street , internet protocol, media access control, telephone number, mobile number, business number, photograph image, x-rays, fingerprints, biometric image, template date(e.g. retain scan, well-defined group of people),vehicle registration number, title number and information about an induvial that is linked or linkable to one of the above (e.g. date of date, place of birth, race, religion, weight, activities, geographical indictors, employment information, medial information, education information, financial information) and etc.

For Choice Neighborhoods, no information about individuals is collected, generated or retained.


4(a) Does the project, program, or system retrieve information from the system about a U.S. Citizen or lawfully admitted permanent resident aliens by a personal identifier?
  No.  Please continue to next question.
  Yes.  If yes, please list all personal identifiers used:

4(b) Does the project, program, or system have an existing System of Records Notice (SORN) that has already been published in the Federal Register that covers the information collected?
  No.  Please continue to next question.
  Yes.  If yes, provide the system name and number, and the Federal Register
citation(s) for the most recent complete notice and any subsequent notices
reflecting amendment to the system

4(c)Has the project, program, or system undergone any significant changes since the SORN?
 No.  Please continue to next question.
  Yes.  If yes, please describe.

4(d) Does the project, program, or system use Social Security Numbers (SSN)?
  No.
  Yes.

4(e) If yes, please provide the specific legal authority and purpose for the collection of SSNs:
Click here to enter text.

4(f) If yes, please describe the uses of the SSNs within the project, program, or system:
Click here to enter text.

4(g) If this project, program, or system is an information technology/system, does it relate solely to infrastructure?

For example, is the system a Local Area Network (LAN) or Wide Area Network (WAN)?
  No.  Please continue to next question.
  Yes.  If a log kept of communication traffic, please answer this question.

4(h) If header or payload data4 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 HUD programs or systems?

  No.
  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-HUD) partners or systems?

  No.
  Yes.   If yes, please list:
Click here to enter text.
6(a) Is this external sharing pursuant to new or existing information sharing access agreement (MOU, MOA, etc.)?

Choose an item.
Please describe applicable information sharing governance in place:

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 HUD personnel?

  No.
I don’t think this question applies as this PTA is not for a system with access needs.
  Yes.   If yes, please list:


    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?
  No. What steps will be taken to develop and maintain the accounting:
Checking “no” because it is not applicable.
  Yes.  In what format is the accounting maintained:
    9. Is there a FIPS 199 determination?5
 Unknown.
 No.
I don’t think this question applies as this PTA is not for a system.
 Yes.  Please indicate the determinations for each of the following:
Confidentiality:
 Low  Moderate  High

Integrity:
 Low  Moderate  High

Availability:
 Low  Moderate  High





PRIVACY THRESHOLD ANALYSIS REVIEW
(To be Completed by PROGRAM PLO)
Program Privacy Liaison Reviewer:
Click here to enter text.

Date submitted to Program Privacy Office:
Click here to enter a date.

Date submitted to HUD Privacy Branch:
Click here to enter a date.

Program Privacy Liaison Officer Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
Click here to enter text.

(To be Completed by the HUD Privacy Branch)
HUD Privacy Branch Reviewer:
Click here to enter text.
Date approved by HUD Privacy Branch:
Click here to enter a date.
PTA Expiration Date:
Click here to enter a date.
DESIGNATION
Privacy Sensitive System:
Choose an item.    If “no” PTA adjudication is complete.

Category of System:
Choose an item.
If “other” is selected, please describe:  Click here to enter text.

Determination:              PTA sufficient at this time.
 Privacy compliance documentation determination in progress.
 New information sharing arrangement is required.
 HUD Policy for Computer-Readable Extracts Containing Sensitive PII applies.
 Privacy Act Statement required.
 Privacy Impact Assessment (PIA) required.
 System of Records Notice (SORN) required.
 Paperwork Reduction Act (PRA) Clearance may be required. Contact your program PRA Officer.
 A Records Schedule may be required.  Contact your program Records Officer.

PIA:
Choose an item.
If covered by existing PIA, please list:  Click here to enter text.

SORN:
Choose an item.
If covered by existing SORN, please list:  Click here to enter text.

HUD Privacy Branch Comments:
Please describe rationale for privacy compliance determination above.
Click here to enter text.



DOCUMENT ENDORSMENT


DATE REVIEWED:
PRIVACY REVIEWING OFFICIALS NAME:


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SYSTEM OWNER
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CHIEF PRIVACY OFFICER
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Date
OFFICE OF ADMINISTRATION