Privacy Threshold Analysis

U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)
Public Housing 5-Year and Annual PHA Plan
0MB Control Number: 2577-0226
Office of Public Housing and Voucher
Programs
Instruction & Template

8/28/19

PRIVACY THRESHOLD ANALYSIS (PTA)

The PTA is a compliance form developed by the Privacy Branch to identify the use of Personally
Identifiable Information (P11) across the Department. The PTA is the first step in the PIT 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-Govemment 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 PIA and SORN templates to complete
and return.

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

Public Housing 5-Year and Annual PHA Plan

Program:

Public and Indian Housing (PIH)

CSAM Name (if
applicable):

Click here to enter text.

.

.

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

0MB Control Number: 2577-0226

CSAM Number
(if applicable):

Click here to enter text.

Form or other Information
Collection

Project or
program
status:

Existing

October 21, 1998

Pilot launch
date:

Click here to enter a date.

Click here to enter a date.

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)
.

.

.

.

PROJECT OR PROGRAM MANAGER
Name:

Bernita James

Office:

PIH

Title:

Housing Program Specialist

Phone:

202-402-7169

Email:

Bernita.C.James @ hud.gov

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.

The Public Housing Agency (PHA) Plan was created by section 5A of the United States Housing Act of
1937(42 U.S.C. 1437c-]). There are two different PHA Plans: the Five-Year Plan and the Annital Plan.
The Five-Year Plan describes the agency’s mission, long-range goals and objectivesfor achieving its
mission over afive-year period. The Annual PHA Plan is a comprehensive guide to PHA policies,
programs, operations, and strategies for meeting local hoitsing needs and goals.

The PHA Plans informs HUD, residents, and the public of the PHA ‘s mission for serving the needs of
low, very low-income, and extretnely tow-income families and its strategy for addressing those needs.
This information helps provide accountability to the local community for how PHAs spend theirfunding
and implement their policies. Also, PHA plans allow HUD to monitor the performance ofprograms and
the performance ofpublic housing agencies that administer them.

HUD’s most recent action in July 2016 was to post revise a version of this collection which 0MB
approved as afttll revision incorporating pttblic comments in 2013, and with minor changes in late 2014.
Pttblic commenters ttrged HUD to return to earlier multiple versions of PHA Plan templates by specific
PHA type instead of a “One-Size Fits All” form. The 2016 forms were not made public due to ongoing
changes of related policies.
With this cttrrent proposed information collection, HUD intends to further mothfy the HUD-50075-5Y,
HUD-50075-ST, HUD-50075-SM, HUD-50075-HCV, HUD-50075-HP templates and HUD-50077 Civil
Rights, PHA Plan, Related Regulations, and Consistency with State/local Consolidated Plan
certUications in the following manner as needed without a major overhaul as was done for the 2016
approval:

1) Revise the instructions provided on the Assessment of Fair Housing (AFH) ensuring that program
participants continue to conduct the Analysis of Impediments (Al) to fair hottsing ttntil they are required
to submit an AFH
2) Create a new section on alt certUlcations to give program participants the option to add an
explanation when they cannot certtfy to being fully compliant with the stated regulations and

As stated in the 2016 notice, due to the de-cottpling of Capital Fund Program activities from PHA Plan
submissions, the HUD-50075.1 and HUD -50075.2 Capital Fund Annual Statement/Performance and
Evaluation Report and 5-Year Action Plan forms, and the associated burden hours (10,070) were
removed will be removedfrom the approvalfor the PHA Plan tinder 0MB no. 2577-0226 and added to
the appro vat for the Capital Fund Program under 0MB no. 2577-0157.

2.

Does this system employ the following
technologies?

If yott are ttsing these technologies and want
coverage under the respective PIA for that
technology, please stop here and contact the HUD
Privacy Branch forfttrther guidance.

El

Social Media

[1
LI
LI

a

‘

,

Web portaV (e.g., SharePoint)
Contact Lists

Public website (e.g. A website operated by
HUD, contractor, or other organization on behalf of
the HUD

:

None of these

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

LI
LI
LI
LI
LI

Members of the public
HUD employees/contractors (list programs):
Contractors working on behalf of HUD
Employees of other federal agencies
Other (e.g. business entity)

4. What specific information about individuals is collected, generated or retained?
This collection does not collect, generate or retain specific information about individuals.

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?

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?

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

Informational and collaboration-based portals in operation at
personally identifiable information

(P11)

HUD

and its programs that collect, use, maintain, and share limited

about individuals who are “members” of the portal or “potential members” who seek to

gain access to the portal.
2
HUD detines 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
the Department. “Sensitive

P11”

is

P11,

U.S.

which

citizen, lawful permanent resident, visitor to the

if

harm, embarrassment, inconvenience, or unfairness to an individual.
same.

U.S.,

or employee or contractor to

lost, compromised, or disclosed without authorization, could result in substantial
For the purposes of this

PTA, SPII

and

P11

are treated the

4(c)Has the project, program, or system

No. Please continue to next question.

•

undergone any significant changes since the

SORN?

LI

Yes. If yes, please describe.

4(d) Does the project, program, or system

No.

use Social Security Numbers (SSN)?

Yes.

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

Click here

the project, program, or

to enter text.

system:
4(g) If this project, program, or system is
.

.

No. Please continue to next question.

.

an information technology/system, does it
relate solely to infrastructure?

For example, is the system a Local Area Network
(L4V) or Wide Area Network (WAN)?
4(h) If header or payload data3 is stored in the

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

communication traffic log, please detail the data

elements stored.

Click here to enter text.

5.

No.

Does this project, program, or system
connect, receive, or share P11 with any
other

HUB

programs or systems?

LI

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

No
Yes. If yes, please list:

systems?

Click here to enter text.
.

.

6(a) Is this external sharing pursuant to

new or existing information sharing
access agreement (MOU, MOA, etc.)?

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

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

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.
terminate a logical connection before data is sent.

For

example, these may be used to set up or

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
maintain an accounting of disclosures
of P11 to individuals/agencies who have
requested access to their P11?
9.

Is there a FIPS 199 determination?4

No.

LI

Yes. If yes, please list:

No. What steps will be taken to develop and
maintain the accounting: This Information Collection Request
ICR) collects no personally identifiable information

LI Yes. In what format is the accounting
maintained:
Unknown.
LINo.

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

LI

Integrity:
LI Low LI Moderate

LI High

Availability:
LI Low LI Moderate

LI High

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:

Cllck 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 documentation is needed.
Click here to enter text.

(TO BE COMPLETED BY THE HUD PRIVACY BRANCH)

FIPS 199 is the Rdr IiiIitin Pi iii Siiiidiid Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.
‘

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:

Choose an item.
Choose an item.

Category of System:
Determination:

If “no” PTA adjudication is complete.

If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
New information sharing arrangement is required.
HUD Policy for Computer-Readable Extracts Containing Sensitive P11
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
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•
SORN

Choose an item.
If covered by existing PTA, please list: Click here to enter text.
Choose an item.

If covered by existing SORN, please list: Click here to enter text.
HUD Privacy Branch Comments:
Please describe rationale for privacy compliance 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 policies.

c11tZ’
SYSTEM

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OWNERV

8-28-19
Date

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CHIEF PRIVACY OFFICER
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OFFICE OF ADMINISTRATION