PTA - BOR Paleo Resources System

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:

Paleontological Resources Protection – an inter-bureau
project (rulemaking) between the U.S. Fish and
Wildlife Service, Bureau of Reclamation, Bureau of
Land Management, and National Park Service.

B. Bureau or Office:

Bureau of Reclamation

C. Program or Office:

Environmental Compliance Division

D. Project/Program Manager or System
Owner:

Name: Joseph Giliberti

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: Federal Preservation Officer
Phone: 303-445-3206
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: 3-1-2022

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Section 2. Project, Program or System Summary
Question

Response

A. General description of the project, program
or system. Please provide the utility of the
program; how

This program will protect and preserve paleontological
resources as required in the Paleontological Resources
Please provide a description of the project or program, Preservation Act of 2009 (and its implementing
including any background information to help
regulations). The program will consist of general policy
understand the project, program or system. If this is an and guidance for preserving these resources on Bureau
updated PTA, please describe the changes that
of Reclamation lands and a permitting system for
triggered the update to this PTA. Please also indicate
collection of the materials by qualified researchers for
if the PTA is being updated as part of its annual
reviewed research projects.
review.

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)
_X__Paper-based Collection
___ Other: Describe.

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

_X__ Yes: Please describe.

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.

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.

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

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

Application and permitting forms.
___ No

_X__ Yes: Please provide the status of any information

collection clearance request related to this project, program
or system, and include all OMB Control Numbers and
Expiration Dates that are applicable.
OMB Control Number 1093-0008; pending final approval
upon publication of the final rule.

___ No

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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.

_X__ Federal employees – access through AD

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).

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

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.

C. Is information retrieved by a unique
identifier assigned to the individual?
Describe how information is retrieved for the
project, program or system.
D. Is the information covered by a System of
Records Notice (SORN)? 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 “Yes” and
provide a detailed explanation. For 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.

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

Name, educational and employment information used to
evaluate permit applicants and their research design
submission.
The project collects PII from the public who apply for
paleontological resources use permits; permittees and
persons working under a permit (support personnel);
persons who file a written objection to a proposed notice
of violation and assessment of civil penalty and/or
request a hearing on a final assessment of civil penalty;
DOI employees, contractors, or partners who perform
paleontological investigations for scientific research;
employees located at a facility that curate Federal
collections; and DOI employees who serve as contacts
for processing applications and managing permits.
_X__ Yes: Please describe.
Name, permit number.
___ No
_X__ Yes: Please provide the title, date, and Federal
Register citation.
INTERIOR/DOI-20, Paleontological Resources
Preservation System – 84 FR 52530 (October 2, 2019)
___ No

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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
_X__ Yes: Please describe the PII shared and purpose
of the sharing.
May be shared with other Bureaus as part of joint
research.
___ No

G. Does this Project, Program or System
receive or share PII with any external (nonDOI) partners or systems? i.e., Tribal, state,
or local gov, public or private partners,
NGOs, grantees, other Federal agencies, etc.
and if so, who, how and what for?

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.

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

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.

_X__ Yes: Please describe the PII shared and purpose
of the sharing.
May be shared with other Federal Agencies as part of
joint research; Information may be shared during tribal
consultations concerning potential impact on tribally
associated resources.
___ No

___ Yes: Please describe applicable information
sharing agreement(s) in place.

_X__ No

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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
___ Other: Describe.

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.

Bureau Associate Privacy Officer Comments:

Provide comments or additional guidance on privacy
compliance requirements.

Associate Privacy Officer Name:
Bureau/Office:
Date:

1018-0008 is a paper-based collection so no PIA
necessary. Records are retrieved by a personal identifier
so SORN coverage is required and provided by DOI-20.

signed by REGINA MAGNO
REGINA MAGNO Digitally
Date: 2022.03.03 07:45:27 -07'00'

Bureau of Reclamation
3/3/2022
DOI Privacy Office Comments

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