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.

Privacy Threshold Analysis – IC/Form

Page 1 of 11

Version number: 04-2016

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:

FEMA Form 516-0-1
Federal Hotel and Motel Fire Safety Declaration Form

Component:

Federal Emergency
Management Agency
(FEMA)

Office:

U.S. Fire Administration
(USFA)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title: Federal Hotel and Motel Fire Safety Declaration Form
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:

1660-0068
Extension

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

August 31, 2018
August 24, 2015

PROJECT OR PROGRAM MANAGER
Teressa Kaas
DHS/FEMA/USFA
Title:
Fire Program Specialist
(301) 447-1263
Email:
[email protected]
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Sherina Greene
Records Management
Title:
Program and Management
Analyst

Privacy Threshold Analysis – IC/Form

Page 2 of 11

Version number: 04-2016

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

Phone:

(202) 646-4343

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.
This PTA is being submitted for FEMA’s use of the Federal Hotel and Motel Fire Safety
Declaration Form per the three-year expiration. This is a renewal PTA and there have
been no changes since the last adjudication.
The U.S. Fire Administration (USFA) uses FEMA Form 516-0-1. The Federal Hotel and
Motel Fire Safety Declaration Form collects business information on life safety systems
related directly to fire safety in hotels, motels, and similar places of accommodation
applying for inclusion on the National Master List (NML). Public Law 101-391 requires
FEMA to establish and maintain a list of hotels, motels, and similar places of public
accommodation meeting minimum requirements for protection of life from fire; the list
is known as the National Master List (NML). The referenced law resulted from a series of
deadly fires in hotels and motels, occurring in the 1970’s and 1980’s, with high loss of
life.
The information is collected and distributed through an on-line electronic database
accessed through the USFA website. Information submitted voluntarily by lodging
establishments is reviewed and if the criteria meet the Hotel and Motel Fire Safety Act
requirements, the hotel/motel is given a FEMA ID number and listed on the NML
database. Federal travelers and the public seeking public accommodation with
provisions for life safety from fire; access the NML through USFA’s website on the on-line
database and identify lodging establishments in the area to which they are traveling.
Property owners/general managers, or their designee/delegate (“applicants”), complete
the form, providing property information including property type (i.e., Hotel/Motel, etc.),
General Manager Name, Property Name, Employer/Tax Identification Number, Property
Privacy Threshold Analysis – IC/Form

Page 3 of 11

Version number: 04-2016

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

Street Address, Property/Reservation Phone Number(s), Property Fax Number, Property
Email Address, Website Address (optional), and provisions for life safety from fire. The
form requests specific responses from applicants as to the installation of smoke
detectors in all guestrooms of properties submitted for listing on the NML. In addition,
applicants must indicate if the lodging establishment has an automatic sprinkler system
where the building is four stories or higher. The information is collected and distributed
through an on-line electronic database accessed through the USFA website.
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.
Hotel and Motel Fire Safety Act of 1974, Public Law 101-391, 15 U.S.C. § 2201 et seq.
requires FEMA to establish and maintain a list of hotels, motels, and similar places of
public accommodation meeting minimum requirements for protection of life from fire;
the list is known as the National Master List (NML).

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.)
c. Who will
complete and
submit this form?

☒ 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.).

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.
Privacy Threshold Analysis – IC/Form

Page 4 of 11

Version number: 04-2016

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

(Check all that
apply.)

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

☒ 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.
Click here to enter text.
☐ Paper.
☐ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via the
internet)
https://apps.usfa.fema.gov/hotel/main/onlineRegistration

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.
The USFA collects the following information from property owners/general managers or
their designees:
Name;
Property Street Address;
Property/Reservation Phone Number(s);
Property Fax Number; and
Property Email Address.
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. N/A
☐ 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
Privacy Threshold Analysis – IC/Form

Page 5 of 11

Version number: 04-2016

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

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

☐ Trusted Traveler Number (Global Entry, PreCheck, etc.)
☐ Driver’s License Number
☐ 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
provided notice
at the time of
collection by
DHS (Does the
records subject
have notice of
the collection or
is form filled out
by third party)?

☒ Yes. Please describe how notice is provided.
A privacy notice will be provided.
☐ No.

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
store the data from the form.
USFA Web Farm
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Privacy Threshold Analysis – IC/Form

Page 6 of 11

Version number: 04-2016

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

Click here to enter text.
b. If electronic, how
does DHS input the
responses into the IT
system?

☐ Manually (data elements manually entered). Please
describe.
☒ Automatically. Please describe.
Applicants input responses in the NML database.

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.
☒ By a non-personal identifier. Please describe.
The user would search by a property name or city
and/or state to identify lodging establishments in
the area to which they are traveling.
ADM-11-2 Project Files
Temporary. Cut off at end of project. Destroy 5 years
after cutoff.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
The USFA staff adheres to the FEMA Disposition
that records are
schedule, to ensure compliance with the records
disposed of or deleted
retention schedule, which outlines timelines,
in accordance with
description of files for records destruction, and or
the retention
disposal of relevant documents associated with
schedule?
each grant program.
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.
The NML is available from the USFA website and is accessed by Government
Travelers to identify lodging establishments in the area to which they are
traveling. No PII will be shared.

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.
Privacy Threshold Analysis – IC/Form

Page 7 of 11

Version number: 04-2016

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.
The NML is available from the USFA website and can be accessed by other federal
agencies, state/local partners and the general public seeking public
accommodation with provisions for life safety from fire. No PII will be shared.
☐ 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.

Privacy Threshold Analysis – IC/Form

Page 8 of 11

Version number: 04-2016

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:

Christopher Rogers

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

August 25, 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.)

Click here to enter a date.
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
The USFA does not retrieve information by
personal identifier. Therefore, no System of
Record exist. However, a privacy notice will
be provided

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 the following coverage:
PIA: DHS General Contacts List; and
SORN: N/A.

Privacy Threshold Analysis – IC/Form

Page 9 of 11

Version number: 04-2016

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

1149974
September 26, 2017
September 26, 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 approved this ICR/Form.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
Privacy Threshold Analysis – IC/Form

Page 10 of 11

Version number: 04-2016

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/ALL/PIA-006 General
Contact Lists
If a PIA update is required, please list: Click here to enter text.
SORN:
Choose an item.
If covered by existing SORN, please list: Click here to enter text.
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 is submitting this PTA for the Federal Hotel and Motel Fire Safety Declaration Form
because the previous PTA has an OMB expiration date of 10/31/2018 and the collection
needs to be extended.
The U.S. Fire Administration (USFA) uses the Federal Hotel and Motel Fire Safety
Declaration Form (FEMA Form 516-0-1) to collect business information on life safety
systems related directly to fire safety in hotels, motels, and similar places of
accommodation applying for inclusion on the National Master List (NML). The NML is
established by FEMA to maintain a list of hotels, motels, and similar places of public
accommodation meeting minimum requirements for protection of life from fire.
The DHS Privacy Office finds that is a privacy sensitive form because it collects PII from
members of the public.
The DHS Privacy Office agrees with FEMA’s recommendation. A PIA is required because the
form collects PII from members of the public, however a SORN is not required because
information submitted on the form is retrieved by a non-personal identifier (by property
name or city/state). The DHS/ALL/PIA-006 General Contact Lists PIA provides adequate
coverage and describes this form as one of the qualifying programs or projects in appendix
B. This form includes the necessary Privacy Notice.

Privacy Threshold Analysis – IC/Form

Page 11 of 11

Version number: 04-2016