Pta

U.S. DEPARTMENT OF

HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)

Dispute Resolution – State Certification Form & Information

Office of Manufactured Housing Programs

Instruction & Template

October 23, 2017

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 and Civil Liberties Impact Assessment (PCLIA) 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 PCLIA or SORN is required, the HUD Privacy Branch will send you a copy of the PCLIA and SORN templates to complete and return.

PRIVACY THRESHOLD ANALYSIS (PTA)

Summary Information

Project or Program Name:	Manufactured Housing Dispute Resolution – State Certification Form; Information for Federal Manufactured Housing Dispute Resolution
Program:
CSAM Name (if applicable):	Click here to enter text.	CSAM Number (if applicable):	Click here to enter text.
Type of Project or Program:		Project or program status:
Date first developed:	May 14, 2007	Pilot launch date:	Click here to enter a date.
Date of last PTA update:	Click here to enter a date.	Pilot end date:	Click here to enter a date.
ATO Status (if applicable)		ATO expiration date (if applicable):	Click here to enter a date.

PROJECT OR PROGRAM MANAGER

Name:	Demetress Stringfield
Office:	Office of Manufactured Housing Programs	Title:	Management Analyst
Phone:	202-402-2239	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:

42 U.S.C. 5401-5426, amended on December 27, 2000, by the Manufactured Housing Improvement Act of 2000, Public Law 106-569, required HUD to establish a manufactured housing dispute resolution program for states that choose not to operate their own dispute resolution programs. In order for a state to operate its own dispute resolution program, the states us the HUD Form 310 to certify that its program meets the requirements of 42 U.S.C. 5401-5426, and must recertify every three years. The state does this by filling out the HUD 310 DRSC form and submitting to HUD for evaluation. HUD Form 311 allows persons to provide the federal manufactured housing dispute resolution program information to resolve a dispute, they will need to submit information on the home and parties involved in the dispute.

Note: This is a renewal with no changes from previously approved form.

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

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)

What specific information about individuals is collected, generated or retained?
The type of information collected includes contact information of homeowners which include names, addresses, home serial numbers, and phone numbers.
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: Name, address, home serial numbers, and phone numbers.
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.

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.
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: Savan Group has a contract with the office to assist us with this. Savan is considered a partner to HUD.
6(a) Is this external sharing pursuant to new or existing information sharing access agreement (MOU, MOA, etc.)?	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. Yes. If yes, please list:
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: Paper based collection. Yes. In what format is the accounting maintained:
Is there a FIPS 199 determination?5	Unknown. No. 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:		If “no” PTA adjudication is complete.
Category of System:		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 and Civil Liberties Impact Assessment (PCLIA) 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:	If covered by existing PCLIA, please list: Click here to enter text.
SORN:	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:

By signing below, you attest that the content captured in this document is accurate and complete and meet the requirements of applicable federal regulations and HUD internal policies.

SYSTEM OWNER << TERESA B. PAYNE, ACTING ADMINISTRATOR		Date
<< OFFICE OF MANUFACTURED HOUSING PROGRAMS>>
CHIEF PRIVACY OFFICER <<INSERT NAME/TITLE>>		Date
OFFICE OF ADMINISTRATION

2 Informational and collaboration-based portals in operation at HUD and its programs that collect, use, maintain, and share limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who seek to gain access to the portal.

3 HUD defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the identity of an individual to be directly or indirectly inferred, including any information that 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. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the same.

4 Header: Information that is placed before the actual data. The header normally contains a small number of bytes of control information, which is used to communicate important facts about the data that the message contains and how it is to be interpreted and used. It serves as the communication and control link between protocol elements on different devices.

Payload data: The actual data to be transmitted, often called the payload of the message (metaphorically borrowing a term from the space industry!) Most messages contain some data of one form or another, but some actually contain none: they are used only for control and communication purposes. For example, these may be used to set up or terminate a logical connection before data is sent.

5 FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal Information and Information Systems and is used to establish security categories of information systems.

United States Department of Housing and Urban Development

January 21, 2021