Privacy Threshold Analysis (PTA) Form - Signed

U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)
Public Housing Operating Subsidy Appeals
-

Financial Management Division

February 4, 2019

PRIVACY THRESHOLD ANALYSIS (PTA)

The PTA is a compliance form developed by the Privacy Branch to identify the use of Personally
Identifiable Information (PIT) across the Department. 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,

•

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:
John Bravacos, Senior Agency Official for Privacy
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 PTA and SORN templates to complete
and return.

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

Public Housing Operating Subsidy Appeals

Program:

Public and Indian Housing (PIll)

CSAM Name (if
applicable):

Click here to enter text.

.

.

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

.

-

CSAM Number

.

.

Click here to enter text.

Form or other Information
Collection

Project or
program
status:

Existing

September 19, 2005

Pilot launch
date:

Click here to enter a date.

February 18, 2016

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)

.

(if applicable):

PROJECT OR PROGRAM MANAGER

J.

Name:

Kevin

Office:

Financial Management Division

Title:

Director

Phone:

202-402-4192

Email:

Kevin.j [email protected]

Gallagher

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 pit rpose so a non-technical person could
understand. If this is an ttpdated PTA, please describe what changes and/or ttpgrades triggering the
ttpdate 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 is a request for renewal of the 0MB Control Number of an existing project—no changes in the
project have been made.

2. Does this system employ the following
technologies?
If iou are using these technologies and want
coverage tinder the respective PIA for that
technology, please stop here and contact the HUD
Privacy Bi-anchforfitrther guidance.
.

fl

Social Media
Web portal’ (e.g., SharePoint)

D

Contact Lists

Public website (e.g. A website operated by
HUD, contractor, or other organization on behalf of
the HUD
x None of these

x This program collects no personally identifiable
information2
3. From whom does the Project or
Program collect, maintain, use, or
disseminate information?
Please check all that apply.

Members of the public
HUD employees/contractors (list programs):

.

U

Contractors working on behalf of HUD
Employees of other federal agencies

x Other (e.g. business entity)—PHAs (voluntary)

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, 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 P1!” is P11, which if lost, compromised. or disclosed tvithout 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 spectfic 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 identtfication number, patient identification ii umber, financial account, credit card
number, street, internet protocol, media access control, telephone number, mobile number, business
number, photograph image, I-rays, fingerprints, biometric image, template date(e.g. retain scan, welldefined group ofpeopte),vehicle registration nttmber, 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.

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?

x No. Please continue to next question.

LI 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?

x No. Please continue to next question.
LI 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

x No. Please continue to next question.

SORN?

LI

Yes. If yes, please describe.

4(d) Does the project, program, or system
use Social Security Numbers (SSN)?
4(e) If yes, please provide the specific legal
authority and purpose for the collection of

Click here to enter text.

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

Click here to enter text.

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

x No.

LI

Yes.

x No. Please continue to next question.

LI Yes. If a log kept of communication traffic,
please answer this question.

For example, is the system a Local Area Network
(IAN) or Wide Area Network (WAN)?
4(h) If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.
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

Click here to enter text.

5. Does this project, program, or system
connect, receive, or share P11 with any
other HUD programs or systems?

x No.
Yes. If yes, please list:

Click here to enter text.
6. Does this project, program, or system
connect, receive, or share P11 with any
external (non-HUD) partners or
systems?

x No.

L

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.)?

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?
8.

Per NIST SP 800-53 Rev. 4, Appendix

J, does the project, program, or system

9.

maintain an accounting of disclosures
of P11 to individuals/agencies who have
requested access to their P11?
Is there a FIPS 199 determination?1

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

x No.

LI

Yes. If yes, please list:

x No. What steps will be taken to develop and
maintain the accounting:

LI

Yes. In what format is the accounting

maintained:

LI Unknown.
x No.

LI

Yes. Please indicate the determinations for each
of the following:
Confidentiality:
Low
Moderate

LI

LI

LI High

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.
FIPS 199 is the l&t,il tnIurniuici li’,iiic Stinjud Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Integrity:
LI Low LI Moderate

LI High

Availability:
LI Low LI Moderate

LI 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 docttmentation 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.

Choose an item.

Category of System:
Determination:

Choose an item.
.

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

LI 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 PIT
applies.

LI Privacy Act Statement required.
LI Privacy Impact Assessment (PIA) required.

System of Records Notice (SORN) required.

E 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 PJA, please list: Click here to enter text.
Choose an item.

If covered by existing SORN, please list: Click here to enter text.
HUB Privacy Branch Comments:
Please describe rationale for privacy comptian ce 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

Date

SYSTEM OWEI{’
Kevin ,J. Gallagher, I)irector
Financial Management Division, Office of Pctblic
Housing Programs

Date
CHIEF PRIVACY OFFICER

<>
OFFICE OF ADMINISTRATION

HUD is committed to protecting the privacy of individuals’ information stored electronically or in paper
form, in accordance with federal privacy laws, guidance, and best practices. HUD expects its third-party
business partners, including Pttblic Housing Authorities, who collect, ttse maintain, or disseminate HUD
information to protect the privacy of that information in Accordance with applicable law.