Privacy Threshold Analysis

DI-4012 (9/2018)
U.S. Department of the Interior

U.S. Department of the Interior
PRIVACY THRESHOLD ANALYSIS

The DI-4012 Privacy Threshold Analysis (PTA) form helps Department of the Interior (DOI) Privacy
Officials determine whether a new or revised Privacy Impact Assessment (PIA) is required in
accordance with the E-Government Act, OMB policy, and the DOI PIA Guide, and identify other related
compliance requirements for the collection, maintenance, storage, use, processing, sharing or disposal of
personally identifiable information (PII) and any activities that may have privacy implications or
otherwise impact individual privacy. See the DOI PTA Guide for guidance on completing the PTA.
PTAs must be completed and submitted to the appropriate Bureau/Office Associate Privacy Officer for
review and compliance determination. Bureau/Office Associate Privacy Officers are responsible for
overseeing and managing PTAs for their organizations.

Section 1. General Information
Question

Response

A. Project, Program or System Name:

Native Youth Community Adaptation and Leadership
Congress (NYCALC)

B. Bureau or Office:

FWS

C. Program or Office:

NCTC

D. Project/Program Manager or System
Owner:

Name: Jennifer Hill

Provide the name for the project, program or system for
the PTA, which may be an IT system, a project title,
program area, information collection, or other
technology.
Enter the bureau or office for the project, program or
system.
Provide the name of the program or office within the
bureau/office.

Enter the name, title, phone number, and email address
of the Program Manager or System Owner.

Title: Congress Coordinator
Phone: 304-876-7441
E-mail: [email protected]

E. Routing Information:

Indicate whether this is a new or updated PTA and enter
the date the PTA was completed and submitted to the
APO for privacy determination.

_X__ New PTA
___ Updated PTA
Date of Submission: 10/3/2019

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Privacy Threshold Analysis

DI-4012 (9/2018)
U.S. Department of the Interior

Section 2. Project, Program or System Summary
Question

Response

A. General description of the project, program
or system.

The New Mexico Wildlife Federation (NMWF) holds
an annual youth conservation training conference at
NCTC via a cooperative agreement with FWS.

B. What is the technology or format used for
the Project, Program or System?

___ IT System
___ New Project or Program
___ Website
___ Web Form, Survey or Information Collection
___ Third-Party Website
___ Social Media Application
___ SharePoint
___ Mobile Application
___ Closed Circuit Television (CCTV)
___ Paper-based Collection
_X_ Other: Federal and non-governmental
collaborative program

C. Does this project, program or system
involve a form, survey or information
collection?

_X_ Yes: NMWF collects applicant data via their
website, email and Google forms.

If this project, program or system uses a form, survey,
or other information collection, select “Yes” and
describe the specific method or format used. Include
titles and numbers or other identifying information.

___ No

D. Is Office of Management and Budget
(OMB) approval required for the collection?

_X_ Yes: FWS PERMA is working with the program to

Please provide a description of the project or program,
including any background information to help
understand the project, program or system. If this is an
updated PTA, please describe the changes that
triggered the update to this PTA. Please also indicate
if the PTA is being updated as part of its annual
review.

Select all types of technology or sources that apply for
the PII that will be collected from or maintained on
individuals, including methods such as a paper or
electronic form or survey, website collection, social
media, or interviews over the phone or in person.

OMB approval is required for certain collections of
information from ten or more members of the public
under the Paperwork Reduction Act.

obtain OMB approval.

___ No

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Privacy Threshold Analysis

DI-4012 (9/2018)
U.S. Department of the Interior

Section 3. Personally Identifiable Information
Question

Response

A. What categories of individuals does the
Project, Program or System collect, maintain,
store, use, process, disseminate or dispose of
PII? Please select all that apply.

___ Federal employees

Indicate whether the project, program or system
collects, contains, uses or disseminates PII
information about members of the general public,
Federal employees, contractors, or volunteers; or if
the system does not contain any information that is
identifiable to individuals (e.g., statistical,
geographic, financial).

___ Contractors
_X_ Members of the public
___ Other: Describe.
___ This project, program or system does not collect,
maintain or process PII

B. What specific information about
individuals will be created, collected, used,
processed, maintained or disseminated?

Applicant/attendees who are rising high school seniors
aged 16-18: name, DOB, community/Tribal affiliation,
address, phone number, mentor’s name, school name &
address, grade, email address, emergency contact
information, parental/guardian consent, medical & health
information in the case of an emergency.

C. Is information retrieved by a unique
identifier assigned to the individual?
Describe how information is retrieved for the
project, program or system.

___ Yes: Please describe.

D. Is the information covered by a System of
Records Notice (SORN)?

___ Yes: Please provide the title, date, and Federal
Register citation.

Describe all the types of information about
individuals that will be created, collected, used,
processed, maintained, or disseminated. Include any
new information that may be created, such as an
analysis or report. Describe the purpose of that
collection or use of information.

___ No:
Not applicable. Records are maintained, categorized and
retrieved by NMWF - not FWS.

The Privacy Act requires that agencies publish a
SORN in the Federal Register upon the establishment
of a new, or modification of an existing, system of
records. For new SORNS being developed, select
_X_ No: Records are maintained, categorized and
“Yes” and provide a detailed explanation. For
retrieved by NMWF and not FWS.
existing systems of records, identify the applicable
government-wide, DOI, or bureau SORN(s) that
covers the system of records with the SORN identifier
and Federal Register citation.

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DI-4012 (9/2018)
U.S. Department of the Interior

Question

Response

E. Does the Project, Program or System
collect or use Social Security Numbers
(SSNs)?

___ Yes: Please provide the legal authority for the
collection of SSNs and describe the uses of the SSNs
within the Project, Program or System.

List the statutory and regulatory authority and
Executive Orders that authorizes the collection or
use of SSNs to meet an official program mission or
goal.

F. Does this Project, Program or System
receive or share PII with any other internal
DOI programs or systems?
Indicate whether PII will be shared with or from
internal organizations within DOI.

_X_ No
___ Yes: Please describe the PII shared and purpose of
the sharing.

_X_ No

G. Does this Project, Program or System
receive or share PII with any external (nonDOI) partners or systems?

_X_ Yes: All applicant and attendee records are
maintained, categorized and retrieved by NMWF.

Indicate whether PII will be shared with agencies or
organizations external to DOI. This could be other
federal, state and local government agencies, private
sector entities, contractors or other external third
parties. For Privacy Act systems, identify the
applicable SORN and describe how an accounting of
the disclosure is maintained.

___ No

H. Is this external sharing pursuant to new
or existing information sharing agreement
(Memorandum of Understanding,
Memorandum of Agreement, Letters of
Intent, etc.)?

_X_ Yes: Cooperative Agreement.

Information sharing agreements are generally
documented in Memorandums of Understanding,
Memorandums of Agreement, Letters of Intent, or
other documents, and outline the purpose, roles of
the parties, data ownership, authorized uses, policy,
scope, standards, procedures, practices, limitations
on re-dissemination, and safeguard requirements for
the transfer, maintenance and disposal of PII to
ensure all parties understand and adhere to the
mutually established terms of the agreement.

___ No

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[Title]
Privacy Threshold Analysis

DI-4012 (9/2018)
U.S. Department of the Interior

Section 4. PTA Review and Recommendation
Question

Response

Privacy Compliance Determination:

_X_ PTA is sufficient at this time
___ Privacy Impact Assessment (PIA) required
___ Adapted PIA required
___ System of Records Notice (SORN) required
___ Notice of Proposed Rulemaking/Final Rule required
___ Computer Matching Notice required
___ Computer Matching Agreement required
___ Privacy Act Statement required
___ Privacy Notice required
___ Specialized role-based training required
___ Information sharing agreement required
___ Further privacy compliance review is required
___ Refer for Security Compliance Assessment
___ Refer for Information Collection Clearance Review
___ Refer for Records Review
_X_ Other: FWS Privacy is working with NCTC
Contracting Officer to ensure responsibilities for
information security and privacy protections are
addressed adequately in the cooperative agreement.

Bureau Associate Privacy Officer Comments:

The NYCALC is not a Government information
technology system or system of records. The conference
is coordinated and held by NMWF with assistance from
FWS NCTC staff and access to FWS facilities. FWS is
not responsible for the personal information of NYCALC
attendees or applicants collected by the NMWF.

Associate Privacy Officer Name:

Jennifer L. Schmidt

This determination is to be completed by the
Associate Privacy Officer (APO). See DOI PTA
Guide, DOI PIA Guide, related Federal laws and
policies, and Departmental guidance on privacy
requirements.

Provide comments or additional guidance on privacy
compliance requirements.

Bureau/Office:
Date:

JENNIFER
SCHMIDT

Digitally signed by
JENNIFER SCHMIDT
Date: 2020.01.08
10:40:50 -05'00'

DOI Privacy Office Comments

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