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.

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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:

TSA Form 1904A

Form Title:

End of Course Level 1 Evaluation – Instructor-Led Classroom
Training

Component:

Transportation Security
Administration (TSA)

Office:

Office of Training &
Development (OTD)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Click here to enter text.
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:

1652-0041
Revision

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

September 30, 2018
Click here to enter
a date.

PROJECT OR PROGRAM MANAGER
Virginia Beauman
OTD
Title:
Section Chief
[email protected]
210-396-4404
Email:
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Glenn Stoll

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

Office:

Phone:

Information Management
Title:
Director of IMPS/Forms
Program Section (IMPS),
Management Officer
OED, OIT
571-227-5175
Email:
[email protected]
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.
The information obtained from the TSA 1904A, End of Course Level 1 – Classroom
Training form provides valuable feedback to staff of the TSA OTD Canine Training
Center (CTC) and is used to evaluate and improve the effectiveness and efficiency of
instructional programs. The PRA is triggered in this instance for CTC because Level 1
feedback must be collected from legacy civilian canine handler students who attend
either the CTC Explosives Detection Canine Handlers Course, Passenger Screening
Canine Handler Course, or the Supervisor/Trainer Seminars Course. The 1904A form
is an extension of OTD’s broader evaluations program and training standards, which
include use of the Kirkpatrick Evaluation Model to measure and evaluate training
effectiveness.
CTC students who successfully complete the above courses, complete the 1904A form
to provide participant reaction to course content, materials, learning environment,
and instructor performance. This provides valuable feedback to both those at the
local level, such as the CTC Supervisory Air Marshal in Charge (SAC), instructional
staff, and supervisors, and to those evaluating data at the headquarters level, with
respect to the presentation and receipt of training material. The feedback is used to
improve the course curriculum and course of instruction.
Since obtaining OMB approval on the 1904A form on September 27, 2013, OTD has
sought to streamline OTD’s Level 1 evaluation collection into a single, consolidated
Level 1 Evaluation form that can be used for all students, both TSA employees acting
within the scope of their duties and the legacy CTC civilian students in any of the
courses listed above. To accomplish this, OTD is revising the previously OMB
approved 1904A. The revisions are primarily cosmetic, non-substantive changes,
particularly from a PRA perspective (since there are no new added imperatives to
collect additional information beyond what is already requested via the approved
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

TSA Form 1904A). Changes include adding three more Instructor sections, as there is
the potential for more than 3 instructors to deliver the training, eliminating
redundancies in the evaluation items, updating the rating scale from a numerical
(N/A; 1-5) to a radial rating scale (Strongly Disagree, Disagree, etc.) in accordance
with DHS.
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.
Aviation and Transportation Security Act (ATSA) 49 USC 107 – 71; Government
Performance and Results Act of 1993, Public Law 103-62

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? (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.
☒ 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

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

☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.
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.
No PII is allowed on the survey as noted on the form.

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.
☐ 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
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:
g. List the specific authority to collect SSN or these other SPII elements.
N/A

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

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.
The individuals are notified the first day of class
and prior to the actual evaluation being conducted.
☐ 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.
TSA’s Performance Information Management
System (PIMS)
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
b. If electronic, how
does DHS input the
responses into the IT
system?

Privacy Threshold Analysis – IC/Form

☒ Manually (data elements manually entered). Please
describe.
Completed forms are submitted by TSA employees
to TSA’s Online Learning Center. Completed forms
are submitted by non-TSA personnel through
TSA’s authorized survey tool, Vovici. The
evaluation responses are then exported from OLC
and Vovici via Excel into PIMS.

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

☐ Automatically.
c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?
d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?

☐ 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.
User may search the information submitted on the
forms by course title, course date range, or TSA
Online Learning Center (OLC) identifier.
Records are managed in accordance with TSA’s
Records Disposition Schedule 1900.1.1-a/GRS 2.6
Item 010. They are destroyed when 3 years old, or 3
years after superseded or obsolete, whichever is
appropriate, but longer retention is authorized if
required for business use.
CTC Response: Dates are established on the folders
and the responsible persons review the folders
annually to ensure compliance with file maintenance
requirements.

HQ Response: Records will be retained indefinitely as
they are required for business use, namely
comparison of past results with future results and
curriculum reviews on a five-year cycle, at a
minimum. Individual records will not be retrieved,
rather results will be viewed in the aggregate.
f. Is any of this information shared outside of the original program/office?
☐ Yes, information is shared with other DHS components or offices. Please describe.
☐ 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.
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

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:

Jennifer L. Schmidt

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

November 8, 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.)

November 9, 2017
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Not privacy sensitive collection.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
TSA Privacy office recommends approval of this PTA. TSA Form 1904A, End of Course
Level 1 – Classroom Training does not collect PII and the responses are not retrieved
by a personal identifier. No PIA or SORN coverage is necessary.

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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:

Sean McGuinness

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1153550
November 14, 2017
November 14, 2020

DESIGNATION
Privacy Sensitive IC or
Form:

No 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 not received 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
e(3) statement not required.
Statement:
Click here to enter text.
PTA:
No system PTA required.
Click here to enter text.
PIA:
Choose an item.
If covered by existing PIA, please list: Click here to enter text.
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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 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.
DHS Privacy Office finds that the End of Course Level 1 Evaluation – Instructor-Led
Classroom Training, TSA Form 1904A is non-privacy sensitive as it does not collect
PII.
TSA Form 1904A allows Canine Training Center (CTC) students to provide feedback
to the staff of the TSA OTD CTC with their opinions on the courses. No PII is collected
on this form as the student answers the survey with the following options (Strongly
Agree, Disagree, etc.) along with three sections students can provide comments on
their learning experience. This form is being revised to streamline OTD’s Level 1
evaluation collection into a single, consolidated Level 1 Evaluation form that can be
used for all students, both TSA employees acting within the scope of their duties and
the legacy CTC civilian students in any of the courses involved.
PIA/SORN coverage is not required as TSA Form 1904A does not collect PII.
A Privacy Act Statement is not required as information on this form is not retrieved
by personal identifier.

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