Privacy Threshold Analysis (PTA) Form

U.S. DEPARTMENT OF

HOUSING AND URBAI{ DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)

Application for Membership on the Housing
counseling Federal Advisory committee
(HCFAC) 2s02-0606
Office of Housing Counseling
office of outreach and capacity Building

November 26,2019

United States Department of Housing and Urban Development
Decem ber 2, 20

I

9Novem6srr6?+l-9

PRIVACY THRESHOLD ANALYSIS (PTA)
The PTA is a compliance form developed
by tlie privacy Branch to identifl, the use of personally

Identifiable Information (PII) across the Department.
The
process, which focuses on these areas
of inquirv:

.
.
'
.
.

prA

is the first step in the

p1 verification

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 Liberlies 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

program Privacy Liaison officer, please send the

officer (plo), If you have no
prA to the HUD privacy Branch:

John Bravacos, Senior Agency Official for privacy
Privacy Branch
U.S. Department of Housing and Urban Developrnent

[email protected]

Upon receipt from your program PLo, the HUD Privacy Branch will review this form. If pcLIA
a
or
SORN is required, the HUD Privacy Branch

will

send yoLr a copy of the PCLIA and SORN templates to

complete and return.

United States Department of Housing and Urban Development
December 2,

20l9Nevembe*.7639+9 2

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

Application for Membership on th; Ho-usi'g c",rr,.eli;g-necr-erar
aovisory
Committee (HCFAC) 2502-0606

Program:
CSAM Name
applicable):

(if

Type ofProject or

Program:
Date first
developed:
Date of last PTA
update:

ATO Status
applicable)

(if

N/A

CSAMNumber | -_
(if applicabte)r 1 xlo

Form or other Information
Collection

Project or
program
status:

October 14,2013

Pilot launch

November 1 ,2011

Pilot end date:

N/A

NiA

ATO
expiration date
(if applicable):

N/A

Existing

N/A

date:

PROJECT OR PROGRAM MANAGER
Name:

Virginia F. Holman

Office:

Office of Housing Counseling

Title:

Housing Specialist

Phone:

(cell) 540-894-7790

Email

Viri ginia.f. holman@hud. gov

INFORMATION SYSTEM SBCURITY OFFICBR (TSSO) (IF APPLICABLB)
Namb:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

United States Deparlment of Housing and Urban Development
D_gcember 2,

2019Nsvemberafa40+g

3

SPECIFIC PTA QUESTIONS

1.

Reasqn

for,submittingm

The Dodd-Frank Act (the Expand and Preserve
Homeownership through counseling Act, public
Law 1ll-203, titleXIV, $ 1441 , July 21,2010,124
Stat. 2t63 (Act), iz t-lsc 3533(g) directs the
of Housing Counseling to form a t-lousing Counseling
Federal Advisory committee
(HCFAC) with l2 members representing the mJrtgage
and real estate industrils, housing
consumers and housing counseling agencies. rhe
Hun-g0005, Application fbr Membership on
the Housing

9fllt

Counseling Federal Advisory Committee will collect
information fbr individuals in
pll changes to the
information previously approved by OMB.
those groups who want to serve on the HCFAC. There
have been no

The information to be collected uses HUD-90005, Application
for Membership on the Housing
Counseling Federal Advisory Committee. The information will
be used by uuo,s office of
Hous.ing counseling (oHC) to review applications and
to recommend to the Secretary fbr
appointment the members of the HCFAC to ensure the members
meet the requirements of the
Expand and Preserve
through Counseling Act , the Federal Advisory Committee
-Homeownership
Act and the HCFAC Charter.
Nominations may be made by agency officials, members of
Congress, the general public, professional organizationr, und the nominee.
Nominations can be
made anywhere in the country.

2,

Does this system employ the following
technotogies?
If you are using these technologies and wqnt
coverage under the respective PIAfor that
technologt, please stop here and contact the H(/D
Privacy Branch for further gu idance.

I
I

Social Media

I
!

Contact Lists

WeU portalr (e.g., SharePoint) Sharepoint is
used to store information

eubtic website (e.g. A website operated by
HUD, corrtractor, or otlrer organizatiot'r orr behalf of
the HUD

I

None of these

-

rlnformational

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.

United States Deparlment of Housing and Urban Development
December

,2,

20l9November26;419 4

[

't'tris

program collects no personally iclentifiable

inlbrnrationr

J.

From whom does the project or
Program collect, maintain, use, or
disseminate information ?
Please check qll that apply.

I
f

HUO employees/contractors (list programs):

OHC, OCFO (Travel/per diem Voucher
Records), OGC (OG E-450)

f]
I
f
4'

Members of the pLrblic

Contractors working on behalf of HUD
Employees of other f-ederal asencies
Other (e.g. business entity)

What specific information about individuals is collectedo generatecl
or retained?

first and last name, mailing address, telephone number, cell phone
number,
T:::g^i?lt:ltg"t
address, business email address, and employer with address.
Applicants
will
,''
f|P:t"ail
demographic.information: race, ethnicity, ur-ta
other
biographic;i;;;
i.na"r.
f:]]*
requested. Resumes are submined

f:j:::t3*ttll1:tT*to:,is
provlde Pll' l'here is no OHC requiredformatforresumes,

as parr

ortne Hub- e0005 and may

butresumes may have dates of birtt andl

EIC_EL rePorts which.are pulled from SharePoint are reviewect o,rlyu;'oHC
,oiru"a
:jl.::,llt^T:.t'tl".
rtousmg
Management The OGE-450 collects PII but only OCG review the fonn. Members
Traveliper
diem vouchers submitted through the contracting offi.", n.ruy contain pll
which is not shared.

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?

L_l No. Please coutinue to next question.
f, Ves. lf yes, please list all personal identifiers
used: Applicants legal frrst and last name,

mailing address, telephone nurnber, cell phone
nunrber. personal cmail aciclrcss, business email
address, and employer with address.

X No Please cor-rtinue

to next

q".iti"r, p*t

4(b) Does the project, program, or system
have an existing System of Records Notice
(SORN) that has already been published in

SORN and PIA have been sr-rbrnitted to the privacv
Office fbr approval.

the Federal Register that covers the

l_J Yes. If yes, provide the systern name and
number, and the Federal Register
citation(s) for the rlost recent complete notice and
anV sLrDseoLleltt notlces

information collected

?

2

HUD defines personal information as "Personally lclentitlable Infbrrnation" or Pll, rvhich is any inlbrrnation that permits the
identity of an individual to be directly or indirectly inf'erred, including any intbrmation rhat is linked or linkable to rhat inclividual,
regardless o1'whether the individual is a tJ.S. citizcn, larvfirl pcrmanent rcsiclent. visitor to thc tJ.S.. or employee or contractor to
the Department. "Sensitive PII" is PIl. which if losl. conrpromiscd. or disclosecl r,rithout autholization. could result in substantial

hi}rm,embarraSS]Ienl,ini;onvenience"orttn1airncss1oaninclividLraj'l.or|heptI|poses()l'thiSP.I.A.SPIlandl)IIaretI.eatelhc

[.]nited States Departntent of Housing and tJrban Development
Decernber 2, 20 l9Novetnber.?6;?O-19 5

L.ngryg amendmenit;

offi.rn

4(c)Has the project, p.og.urn,
any significant changes since the

tk

s),srem

Xo.

llffi*;".

X

I

Yes. If yes, please describe.

4(d) Does the project, program,
"",V.t-use Social Securifi Numbers (SSN)?

X
f

No.

If ves, please proot-" tt *p".ln" Ggut
"
authority and purpose for the
collection of
4(e)

Please continue ro next qLrestion.

ves.

Not applicable.

SSNs:

4(f)

If

SSNs

yes, please descri be the uses of tt
rvithin the project, program, or

e

system:

4(g)

Il

this project, program, o.

,yrG- i,

X fo. Please continue to next question.
! Ves. If a log kept of communication trafllc,

an information technology/system, does i1

relate solely to infrastructure?

please altswer this question.

Fbr example, is the syste:m a Local Area Network
or ll/ide Area Network MAN)?
4-(li) If header or payload datat
elements stored.

5.

Does this project, program, or system

connect, receive, or share

6.

pII with an;

LJ

No.

f

Ves. If yes, please

list:

other HUD programs or s1'stems?

The OGE-450 is received and reviewed ONLy by
OCG. OHC staff never see the forms. The
travel/Per-diem voucher is received by OCFO
and reviewed and approved by OHC.

Does this project, program, or svstem
connect, receive, or share PII with anp'

X No.

external (non-HUD) partners or

f

systems?

Through the CFO, OHC has a support services
contract. Vouchers submitted through the

Ves. If yes, please

list:

3
Header: Information that is placed before the actual data. The header nonnally contains a small number
of bytes of
control information, which is used to communicate important facts about the data that the message contains und ho*
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 datato be transmitted, often called the payload of the message (metaphorically
borrowing a
term from the space industry!) Most messages contain sonre data of one form o. unothrr, buisome actually contiin
none: they are used only for control and communication purposes. For example, these may be used to iet
up or
terminate a logicai connection before data is sent.
United States Depaftrnent of Housing and Urban Development
Decernber 2, 20 l9Nsvernber.?6;-?el9 6

contracting officer may contain Fff *fri"n
i. not

[rxisting - Nor applicable.

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

7.

Please describe applicable infonnation sharing

governance in place:

p"ogia-, o, sl.st*m
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all HUD personnel?
Does the project,

[s there a FIPS 199 determination?o

xo.

!

Ves. If yes, please

list:

Ll

Xo. Wlrat steps will be taken to
maintain the accountins:

Per NIST SP 800-53 Rev. 4, Appendix
J, does the projectr progrtrre or system
maintain an accounting of disclosures
of PII to individuals/agencies u,ho have
requested access to their pII?

9,

X

O.u.to*rO

f, Yes. In what format is the accounting
maintained: an Excel spreadsheet is maintained.
Additionally, no disclosures of pll are made oLrtside
the Departntent.

I

Unknown.

X ro.
! Yes. Please indicate the determinations

fbr each

of the following:

Confidential ity:
l_..1 Lor.r [_J Moderare

!

Hign

Moderate

f,

Uign

Availab i lity:
f, Low ! Moderate

tr

High

I

I

ntegri ty:

Low

f

PRIVACY THRBSHOLD ANALYSIS REVIBW
(TO BE COMPLBTED BY PROGRAM PLO)
Program Privacy Liaison Reviewer:
Date submitted to Program privacv

Office:

Nadine Smith
November 26,2019

'

FIPS 199 is the Federal Information Processing Stanglg{ PLrblication 199. Standards lbr Security Categorization of'Federal
Information and Information Systems and is used to establish security catcgories of infbrnrarion systems.

United States Depaftment of Housing and Urban Development
December 2, 20

l9Nevember"6;?Of9 7

Date submitted to HUD p""-Ld),Branclx

November 26.

lloSram Privacy f,iaiso

Please include recommendation below, includinp
what new

iance documentation is needeel.

Request determination the privacy Office for:

o

SharePoint storage of non-Sensitive PII, whetlrer
this storage warrants alternative storage method

and

o

Additionalprivacydocumentatior.tcoverase.

(TO BE COMPLETED BY THE HUD PRIVACY BRANCH)
HUD Privacv Branch n"vi"rner:

Click here to enter text.

Date approved by

Click here to enter a date.

HUn f.i*acy nr.a*t"

PTA Expiration Date:

Click here to enter a oare.

DESIGNATION
Privacy Sensitive System:

Choose an

item. If "no" pTA adjLrdicatio,l

cr.,rpl"t

Choose an item.

Category of System:

If 'oother" is selected,
Determination:

is

I

tTa

|
:

|

sr

please describe: Click lrere to enter text

rfficient at rhis tirne.

Privac' 4 compliance documentation determination in progress.

l_J New iL Lformation sharing anangement is required.

[]rruol 'olicy for Cornputer-Readable Extracts Containi'g Sensitive plI
applies.

i-l

Privac' z Act Statement required.

l_J Privacl , and Civil Liberties Impact Assessment (PCLIA) required.

|
f

| Svstenr

of Records Notice (SORN) required.

Paperu 'ork Reduction Act (PRA) Clearance rnay be required. Contact
your progr am PRA Officer.

I lARecc rds Schedule may be required. Contact your program Records
Officer.
pIA:

I

I

Choose an item.

If covered by existing PCLIA,

If covered by existing SORN,
IfUD Privacy Branch Comments:
d e s cr

list: click

here to enter text,

list: CIick

here to enter text

Choose an item.

SORN:

P Ie as e

please

i

b

e r at i onal e .fo:r pr iv acy

co

mp

prease
I i anc

e d e t er min at

i

o

n ab ov e.

United States Department of Housing and Urban Development
Dgcember 2, 201 9N€v€mbw26,

?s.Ig

8

Click here to enter teit.

DOCUMENT ENDORSMENT
PATE REVIEWED:

PRIVACYREVIEWTN@
By signing below, you attest that the content
captured in this document is accurate and complete
and meet the requirements of applicable
federair"gutution, und HUD internal policies.

W,Y,n
Date

PROGRAM MANAGER

Virginia F. Holman, Housing Specialist
Office of Housing Counselingo Office of Outreach
and Capacify Building.

Date

SENIOR AGENCY OFFICIAL FOR PRIVACY
JOHN BRAVACOS
OFF'ICE OF ADMINISTRATION

United States Department of Housing and Urban Development
Dgcempey

2,2019N€,rromb€rr640lg 9