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pdfPrivacy 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.
Privacy Threshold Analysis – IC/Form
Page 1 of 12
Version number: 04-2016
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:
11000-39
Form Title:
CISA Visitor Request Form
Component:
Cybersecurity and
Infrastructure Security
Agency (CISA)
Office:
Office of the Chief
Compliance and
Security Officer
IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
CISA Visitor Request Form
OMB Control
Number:
Collection status:
Name:
Office:
Phone:
1670-0036
Extension
OMB Expiration
Date:
Date of last PTA (if
applicable):
TBD
October 21, 2019
PROJECT OR PROGRAM MANAGER
Michael Washington
Office of the Chief
Title:
Security Specialist
Compliance and Security
Officer
703-235-1925
Email:
[email protected]
hs.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Privacy Threshold Analysis – IC/Form
Page 2 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
Name:
Office:
Phone:
Mia Bruce
Office of the Chief
Title:
PRA Program Coordinator
Information Officer
202-713-6210
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 Office of the Chief Compliance and Security (OCSO) Officer within the Cybersecurity
and Infrastructure Security Agency (CISA) will submit the following renewal CISA Visitor
Request Form PTA. Information Public Law 107-296 and The Homeland Security Act of
2002, Title II, recognizes the Department of Homeland Security role in integrate relevant
critical infrastructure and cybersecurity information, analyses, and vulnerability assessments
(whether such information, analyses, or assessments are provided or produced by the
Department or others) in order to identify priorities for protective and support measures by the
Department, other agencies of the Federal Government, State and local government agencies
and authorities, the private sector, and other entities while maintaining positive control of
sensitive information regarding the national infrastructure. In support of this mission the
Cybersecurity and Infrastructure Security Agency Office of the Chief Compliance and
Security Officer must maintain a robust visitor screening capability.
The Office of Compliance and Security will only use electronic submission via email of the
collection information using an electronic fillable pdf form. This decision allows for the efficient
collection of information about visits, with minimal cost to the government. The form is
requested by CISA employees or contractors to complete for non-DHS guests visiting CISA
facilities. The form is available via the internal DHS website or by requesting a copy of the
form from the Office of Compliance and Security.
The purpose of this form is to allow security officers to conduct a risk-based pre-screening of
visitors to CISA facilities in accordance with DHS and GSA requirements to pre-screen and
register visitors.
The CISA Visitor Request Form must be completed and submitted to the Office of the Chief
Compliance and Security Officer (OCSO) by a current DHS Headquarters employee or
contractor that is serving as the requestor for the visitor(s) in question.
Privacy Threshold Analysis – IC/Form
Page 3 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
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.
5 U.S.C. 301; the Homeland Security Act, codified in Title 6 of the U.S. Code; 44 U.S.C.
3101; and Executive Order (EO) 9397; EO 12968; and Federal Property Regulations, issued
July 2002, authorize the collection of this information. DHS 121-01-011-01 and 41 CFR parts
102-74 require that visitors to are pre-screened and registered.
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
☐ Law enforcement.
☒ DHS employee or contractor.
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.
Privacy Threshold Analysis – IC/Form
Page 4 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
☐ 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.
Name and phone number of requestor; Name and phone number of point of contact (if different
from requestor); Name and phone number of escort (if different from requestor); Visitor name,
organization, and in some cases the last four digits of visitors’ Social Security number (For
Classified Meetings only).
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
x Other. Please list: Last Four of SSN for
Classified Meetings
g. List the specific authority to collect SSN or these other SPII elements.
Executive Order (EO) 9397 authorizes the collection of this information.
Privacy Threshold Analysis – IC/Form
Page 5 of 12
Version number: 04-2016
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.
Use is generally permitted under 5 U.S.C. §552a(b) of the Privacy Act of 1974, as
amended. This includes using information, as necessary and authorized by the routine
uses published in DHS/ALL-024 Facility and Perimeter Access Control Management
System of Records. Security Officers will use this information to positively identify an
individual and make a risk-based decision to allow entry to an CISA facility. The last
four digits of an individual’s SSN, only collected for classified visits, is used to make
positive identification of an individual in order to verify his or her security clearance(s).
i.
Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the There is a Privacy Act Notice included on the form
providing notice to the requestor.
time of collection by
☐ No.
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?
3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
Forms are printed and stored for thirty days, and are then
completed IC/forms? destroyed
☒ Electronic. Please describe the IT system that will
store the data from the form.
Name, Organization, Date of Visit and Escort Name and
Phone number are stored in a spreadsheet, located on an
SPII approved SharePoint site with limited access, for 3
years (SSN is not recorded)
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
Privacy Threshold Analysis – IC/Form
Page 6 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
b. If electronic, how
does DHS input the
responses into the IT
system?
☒ Manually (data elements manually entered). Please
describe.
Data is manually added to the excel spreadsheet, SSN is
not recorded
☐ Automatically. Please describe.
Click here to enter text.
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.
Users may search using name or date of visit
☐ By a non-personal identifier. Please describe.
Click here to enter text.
These records are managed as Visitor Control Files under
General Records Schedule (GRS) 18, 1960, item 18.
As Visitor Control Files under GRS 18, the visitor logs
will be retained until such time as they are destroyed:
• 5 years after final entry or date of document for areas
under maximum security; or
• 2 years after final entry or date of document for other
areas.
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☐ 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.
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.
Privacy Threshold Analysis – IC/Form
Page 7 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
☒ No. Information on this form is not shared outside of the collecting office.
Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.
Privacy Threshold Analysis – IC/Form
Page 8 of 12
Version number: 04-2016
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:
Cheryl Dyson-Bennett/Scherida Lambert
Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:
November 25, 2020
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.)
December 4, 2020
☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.
Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The Office of the Chief Privacy Officer has reviewed and determined this to be a privacy
sensitive collection that is covered by DHS/ALL-024 Facility and Perimeter Access Control
Management System of Records and DHS/ALL/PIA – 038 – Integrated Security
Management System (ISMS).
Privacy Threshold Analysis – IC/Form
Page 9 of 12
Version number: 04-2016
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:
Kattina Do
DHS Privacy Office Approver (if applicable):
PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date
Max Binstock
0015455
December 4, 2020
December 4, 2023
DESIGNATION
Privacy Sensitive IC or
Form:
Yes 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 approved this ICR/Form.
Date IC/Form Approved December 4, 2020
by PRIV:
IC/Form PCTS Number: Form 11000-39
Privacy Act
e(3) statement update is required.
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
Privacy Threshold Analysis – IC/Form
Page 10 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
PIA:
System covered by existing PIA
If covered by existing PIA, please list:
• DHS/ALL/PIA-039 Physical Access Control System (PACS)
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list:
• DHS/ALL-024 Department of Homeland Security Facility and
Perimeter Access Control and Visitor Management February 3,
2010, 75 FR 5609
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.
CISA is submitting this renewal PTA to discuss the CISA Visitor Request Form. NPPD
is now CISA. The purpose of this form is to allow security officers to conduct a riskbased pre-screening of visitors to CISA facilities in accordance with DHS and GSA
requirements to pre-screen and register visitors.
The form is requested by CISA employees or contractors to complete for non-DHS
guests visiting CISA facilities. The form is available via the internal DHS website or
by requesting a copy of the form from the Office of Compliance and Security. The
Office of Compliance and Security will only use electronic submission via email of the
collection information using an electronic fillable pdf form.
The form will collect name and phone number of requestor; name and phone
number of point of contact (if different from requestor); name and phone number of
escort (if different from requestor); visitor name, organization, and in some cases
the last four digits of visitors’ Social Security number (For Classified Meetings only).
The DHS Privacy Office (PRIV) finds that this form is privacy-sensitive, and a PIA is
required because PII is collected from members of the public, DHS Employees, DHS
contractors, and other federal employees or contractors.
PRIV disagrees with CISA Privacy that DHS/ALL/PIA-038 ISMS PIA provides coverage
because CISA does not share this information with ISMS. PIA coverage is provided by
DHS/ALL/PIA-039 Physical Access Control System (PACS), which covers the use of
the range of functions related to managing physical access by individuals to DHS
Privacy Threshold Analysis – IC/Form
Page 11 of 12
Version number: 04-2016
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy
facilities. PACS are generally comprised of four major functions: visitor management,
physical access control, intrusion detection, and video surveillance.
PRIV agrees with CISA Privacy that a SORN is required because info is being
retrieved by a unique identifier. PRIV agrees with CISA Privacy and finds that SORN
coverage is provided by DHS/ALL-024 Facility and Perimeter Access Control and
Visitor Management, which covers the collection of records related to the
Department’s facility and perimeter access control, including access to DHS
information technology and access to classified facilities, as well as visitor security
and management.
CISA has also submitted a sufficient Privacy Act Statement with this PTA.
Privacy Threshold Analysis – IC/Form
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Version number: 04-2016
File Type | application/pdf |
File Modified | 2021-01-08 |
File Created | 2021-01-08 |