PTA Signed MHS

U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)
Manufactured Housing Survey
Office of Policy Development and Research

Instruction & Template

2/28/2019

Note to ISSO: The American Housing Survey is funded
by HUD and administered by the U.S. Census Bureau.
The data collected by the Census Bureau is maintained in
a Census Bureau System of Records. As such, it is the
Census Bureau’ s responsibility to conduct a Privacy
Impact Assessment.

PRIVACY THRESHOLD ANALYSIS

The Privacy Threshold Analysis (PTA) is a compliance form developed by the Privacy Branch to
identify, across the Department, the use of Personally Identifiable Information (P11). The PTA is
the first step in the P11 verification process, which focuses on these areas of inquiry:
•

Purpose for the information

•

Type of information

•

Sensitivity of the information

•

Use of the information

•

The risks to the information

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is
required under the B-Government Act of 2002 or a System of Records Notice (SORN) is
required under the Privacy Act of 1974, as amended.
Complete the form and send it to your program Privacy Liaison Officer (PLO). If you have no
program Privacy Liaison Officer, please send the PTA to Marcus R. Smallwood, Acting Chief
Privacy Officer, Privacy Branch, U.S. Department of Housing and Urban Development,
451 7th Street, SW, Room 10139, Washington, DC 20410 [email protected].
Upon its receipt from your program PLO, the HUD Privacy Branch will review the completed
form. If it determines that a PTA or SORN is required, the HUD Privacy Branch will send you a
copy of the PTA and SORN templates to complete and return to the Branch.

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Manufactured Housing Survey

Program:

Policy Development and Research (PD&R)

CSAM Name (if
applicable):

N/A

.

Type of Project or
Program:
Date first
developed:
Date of last PTA
update:

CSAM Number
(if applicable):

N/A

Form or other Information
Collection

Project or
program
status:

Existing

February 28, 2019

Pilot launch
date:

Click here to enter a date.

N/A

Pilot end date:

Click here to enter a date.

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

.

.

.

ATO Status (if
.
applicable)

.

PROJECT OR PROGRAM MANAGER
Name:

George Carter

Office:

PD&R

Title:

Survey Statistician, HDAD

Phone:

202-402-5873

Email:

George.R.Carter@ hud .gov

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

N/A

Phone:

N/A

Email:

N/A

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 nontechnical person cotcid
ttnderstand. If this is an updated PTA, please describe the changes and/or tipgrades 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.
The Manufactured Housing Survey (MHS) is a survey funded by HUD and administered by the U.S.
Census Bureau. The results of the survey are communicated to the public via the internet. No P11 is
provided to the public. Information is collected from the general public by the Census Bureau. The
Census Bureau collects this data on behalf of HUD. They information collected in the MHS is stored in a
Census SOR.

2.

Does this system employ the following
technologies?

If yott are using these technologies and want
coverage itnder the respective PIA for that
technology, please stop here and contact the HUD
Privacy Branch forfitrther gitidance.

3.

the project or
collect, maintain, use, or

From whom does
program

LI
LI

Social Media
Web portaV (e.g., SharePoint)
Contact Lists

LI

Public website (e.g., A website operated by
HUD, contractor, or other organization on behalf
of HUD)

LI

None of these

LI

This program collects no personally identifiable
information2

disseminate information?

Please check all that apply.

LI
LI
LI
LI

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) Manufactured
Home Dealers

Informational and collaboration-based portals in operation at HUD, and its programs that collect, use, maintain, and share limited
personally identifiable information (P11) about individuals who are “members” of the portal or “potential members” who seek to
gain access to the portal.
2
HUD defines personal information as “personally identifiable information,” or P11, as 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 P11” is P11, 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 P11 are treated the same.

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 address, internet protocol, media access control, telephone ntcmber, mobile number,
bttsiness nztmber, photograph image, x-rays, fingerprints, biometric image, template date (e.g., retain
scan, well-defined grottp ofpeopte),vehicle registration number, title number, and information about an
individutal that is linked or linkable to one of the above (e.g., date of birth, place of birth, race, religion,
weight, activities, geographical indictors, employment information, medical information, education
information, financial information, etc.
The Censits Bureaut collects the name, address, and telephone number of the respondent.
Collection of these data is authorized by Title 13, U.S.C., Section 8(b) (see Attachment 4) and Title 12, U.S.C.,
Section 1701z-1

Census’s legal authority to condttct surveys on beha If of sponsors in found in Title 13, Section 1535.

4(a) Does the project, program, or system
retrieve information about U.S. Citizens or
lawfully admitted permanent resident
aliens using personal identifiers?

LI
LI

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 the next question.
Yes. If yes, please list all personal identifiers
used:
No. Please continue to the 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

COMMERCE/CENSUS-4 “Economic
Survey Collection.” The notice of proposed
amendment to this system of records was
published in the Federal Register on January
26, 2012 (77 FR 4004).
Please note: this SORN resides with the
Department of Coiizmerce

4(c) Has the project, program, or system
undergone any significant changes since the
SORN?
4(d) Does the project, program, or system
use Social Security numbers (SSN)?

LI

No. Please continue to the next question.
Yes. If yes, please describe.

LI

No.
Yes.

4(e) If yes to 4(d), please provide the
specific legal authority and purpose for the

N/A

collection of SSNs.

4(f) If yes to 4(d), please describe the uses of
the SSNs within the project, program, or

N/A

system.

No. Please continue to next question.
Yes. If a log of communication traffic is kept,
please provide that information here.

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 (MN) or Wide Area Network
(WAN)?

NOT APPLICABLE

4(h) If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.

N/A

5.

6.

Does this project, program, or system
connect, receive, or share P11 with any
other HUB programs or systems?
Does this project, program, or system
connect, receive, or share P11 with any
external (non-HUB) partners or
systems?

No.
Yes. If yes, please list:
NOT APPLICABLE

LI
LI

No.
Yes. If yes, please list:

NOT APPLICABLE

LINo.

LI

6(a) Is this external sharing pursuant to a
new or existing information sharing
access agreement (MOU, MOA, etc.)?

Yes. If yes, please choose from the dropdown
menu below:
Choose an item.
Please describe applicable information sharing
governance in place:
NOT APPLICABLE

7.

Does the project, program, or system
provide role-based training for
personnel who have access, in addition

LI
LI

No.
Yes. If yes, please list:

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.

to the annual privacy training required
of all HUD personnel?

8.

Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of P11 to individuals/agencies who have
requested access to their P11?

NOT APPLICABLE

LI
LI

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained:

NOT APPLICABLE
9. Is there a FIPS 199 determination?4

LI Unknown.
LINo.
LI Yes. Please indicate the determinations for each
of the following:
Confidentiality:
LI Low LI Moderate LI High
Integrity:
LI Low LI Moderate LI High
Availability:
LI Low LI Moderate LI High

NOT APPLICABLE

PRIVACY THRESHOLD ANALYSIS REVIEW
(TO BE COMPLETED BY PROGRAM PLO)
Program Privacy Liaison Reviewer:

Ronald Hill

Date submitted to Program Privacy
Office:
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.
Please review and approve. PTA should be sufficient at this time. Data resides with Department of
Commerce and not with HUD. Information is collected from the general public by the Census Bureau.

FIPS 199 (Fderal Information Procssine Staiidard Publication 199, Standards for Security Categorization of federal Information
and Information Systems) is used to establish security categories of information systems.

The Census Bureau collects this data on behalf of HUD. They SOR that stores the survey information is a
Census SOR.

(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.

Category of System:

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

Determination:

If “no” PTA adjudication is complete.

L PTA sufficient at this time.
LI Privacy compliance documentation determination in progress.
LI New information-sharing arrangement is required.
LI HUD Policy for Computer-Readable Extracts Containing Sensitive P11
applies.

LI Privacy Act Statement required.
LI Privacy Impact Assessment (PTA) required.
LI System of Records Notice (SORN) required.
LI Paperwork Reduction Act (PRA) Clearance may be required. Contact
your program PRA Officer.

LI A Records Schedule may be required.

Contact your program Records

Officer.
Choose an item.
If covered by existing PIA, please list: Click here to enter text.
Choose an item.
SORN
If covered by existing SORN, please list: Click here to enter text.
HUB Privacy Branch Comments:
Please describe rationale for privacy compliance determination above.
Click here to enter text.

PIA•

DOCUMENT ENDORSEMENT

DATE REVIEWED:
PRIVACY REVIEWiNG OFFICIAL’S 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.

/4g

S MOWNER
George Carter, Survey Statistician HDAD
Policy J)eveloprnent and Research

CHIEF PRIVACY OFFICER
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OFFICE Of ADMINISTRATION

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ate

Date