Pta

Privacy 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.

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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:

Form Title:

FEMA Forms FF-104-FY-21-122 (formerly FF 009-0-1, English), FF104-FY-21-122-A (formerly FF 009-0-2, Spanish), FEMA Forms FF104-FY-21-123 (formerly FF 009-0-1T, English), FF-104-FY-21123-A (formerly FF 009-0-1T, Spanish), FEMA Form FF-104-FY21-123-COVID-FA (English), FEMA Forms FF-104-FY-21-125
(formerly FF 009-0-1Int, English), FEMA Form FF-104-FY-21-125A (formerly FF 009-0-2Int, Spanish), FEMA Forms FF-104-FY-21127 (formerly FF 009-0-5, English), FF-104-FY-21-127-A
(formerly FF 009-0-6, Spanish), FEMA Forms FF-104-FY-21-128
(formerly FF 009-0-3, English), FF-104-FY-21-128-A (formerly FF
009-0-4, Spanish), and Request for Information (RFI) (English
and Spanish)
Disaster Assistance Registration –
Streamline Registration Intake (RI)

Component:

Federal Emergency
Management Agency
(FEMA)

Office:

Office of Response and
Recovery (ORR)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Disaster Assistance Registration
OMB Control
Number:
Collection status:

1660-0002

OMB Expiration
Date:
Date of last PTA (if
applicable):

New

Privacy Threshold Analysis – IC/Form

N/A
N/A

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Name:
Office:
Phone:

Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Brian Thompson
ORR
Title:
Coordination Unit Chief
540-686-3602
Email:
[email protected]
s.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Millicent Brown Wilson
ORR
Title:
Records Management Branch
Chief
202-304-2291
Email:
[email protected]
v

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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 Federal Emergency Management Agency (FEMA), Office of Response and Recovery (ORR)
submits this Privacy Threshold Analysis (PTA) for the Streamline Registration Intake (RI) process
information collection. The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford
Act), Public Law 93-288, as amended, is the legal basis for the Federal Emergency Management Agency
(FEMA) to provide financial assistance and services to individuals applying for disaster assistance
benefits in the event of a federally declared disaster. Regulations in 44 CFR, § 206.110 - Federal
Assistance to Individuals and Households implements the policy and procedures set forth in Section 408
of the Stafford Act, 42 U.S.C. 5174, as amended. This program provides financial assistance and, if
necessary, direct assistance to eligible individuals and households who, as a direct result of a major
disaster or emergency, have uninsured or under-insured necessary expenses and serious needs, and are
unable to meet such expenses or needs through other means. Individuals and households applying for
assistance must provide information detailing their losses and needs using the paper forms and/or
webforms detailed below.
Using the forms Streamline Registration Intake forms, applicants for disaster assistance are able to select
the type of assistance they require and only answer questions directly related to the specific types of
assistance they need. This will decrease the number of questions survivors need to answer and reduce the
time to complete their disaster application online or at a FEMA disaster recovery center. Further,
Survivors with business losses, damage to vacation or secondary homes, and unemployment-only needs
will be advised earlier in the process that FEMA does not provide this assistance for these categories.
Instead of FEMA capturing unnecessary data, FEMA will direct these survivors to agencies that can help
them with their needs.
Paper forms are utilized in circumstances, such as power outages, when webforms are not available.
These paper forms are manually transcribed into the webform when resources are available to do so (e.g.
when power is restored). The information collected from applicants is initially entered into Disaster
Assistance Improvement Program (DAIP) platforms such as the Individual Assistance (IA) Survivor
Online Application & Resource Portal (SOAR). DAIP then disseminates the information to National
Emergency Information System (NEMIS) and the other IA IT systems that require the information to
accomplish their purposes in facilitating the IA process (see: Individual Assistance (IA) Program
DHS/FEMA/PIA-049). The information gathered through this process will decrease the amount of time
needed to create a new registration and allow the survivor to skip any irrelevant question that do not
pertain to their damages.
Overall, this collection reflects proposed changes to the disaster assistance application process that will
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

reduce the time and burden in applying for disaster assistance.
The new and updated forms of the RI are as follows:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

FEMA Forms FF-104-FY-21-122 (formerly FF 009-0-1, English) and FF-104-FY-21-122-A
(formerly FF 009-0-2, Spanish), Paper Application – When a federally-declared disaster or emergency
occurs, a tele-registration 800 number and disaster assistance website are published for individuals to
apply for FEMA assistance. In rare circumstances where the system is inaccessible or
telecommunication capabilities are inoperable, FEMA service representatives will record the individual’s
information using paper versions of FF-104-FY-21-122 (formerly FF 009-0-1, English) or FF-104-FY21-122-A (formerly FF 009-0-2, Spanish). Once completed and when the system becomes accessible,
the FEMA representative manually enters the information into NEMIS. Burden hours have decreased by
14,698 due to updated forecasting estimates received from the FEMA RAD based on historical data from
years 2007-2019.
FEMA Forms FF-104-FY-21-123 (formerly FF 009-0-1T, English) and FF-104-FY-21-123-A
(formerly FF 009-0-1T, Spanish), Tele-Registration – When a federally-declared disaster or
emergency occurs, a tele-registration 800 number is published for individuals to call and apply for
assistance. A FEMA service representative interviews individuals over the telephone utilizing the
questions in this information collection and records the information directly into the electronic copy of
FF-104-FY-21-123 (formerly FF 009-0-1T, English) in FEMA’s National Emergency Management
Information System (NEMIS) database. Burden hours have decreased by 317,011 due to updated
forecasting estimates received from the FEMA RAD based on historical data from years 2007-2019.
FEMA Form FF-104-FY-21-123-COVID-FA (English), Tele-Registration, COVID-19 Funeral
Assistance – As a result of the Consolidated Appropriations Act, 2021, a dedicated Call Center phone
number was created for applicants to apply for COVID-19 Funeral Assistance. The currently approved
FF-104-FY-21-123 disaster assistance registration script is used, with staff trained to clarify for
applicants how the current questions relate to COVID-19 Funeral Assistance.
FEMA Forms FF-104-FY-21-125 (formerly FF 009-0-1Int, English) and FEMA Form FF-104-FY21-125-A (formerly FF 009-0-2Int, Spanish), Internet – When a federally-declared disaster or
emergency occurs, a website is published for individuals to apply for disaster assistance through
www.DisasterAssistance.gov, which utilizes FF-104-FY-21-125 (formerly FF 009-0-1Int, English) or
FF-104-FY-21-125-A (formerly FF 009-02Int, Spanish). The information collected is electronically
transferred into the NEMIS database. Burden hours have increased by 169,775 due to a system release
which combined Internet and Smartphone into one comprehensive platform.
FEMA Forms FF-104-FY-21-127 (formerly FF 009-0-5, English) and FF-104-FY-21-127-A
(formerly FF 009-0-6, Spanish), Revocable License – Individuals who qualify for transportable
temporary housing units (TTHU) such as Manufactured Housing Units (MHU), recreational vehicles or
travel trailers, or other fabricated dwellings through FEMA Direct Temporary Housing Assistance are
required to acknowledge and accept conditions for receiving and occupying government property. Once
an individual is determined eligible for Direct Temporary Housing Assistance, FEMA uses the
information collected in FF-104-FY-21-122 (formerly FF 009-0-1), FF-104-FY-21-122-A (formerly FF
009-0-2), FF-104-FY-21-123 (formerly FF 009-0-1T), FF-104-FY-21-125 (formerly FF 009-0-1Int), or
FF-104-FY-21-125-A (formerly FF 009-0-2Int) to prepare the Manufactured Housing Unit Revocable
License and Receipt for Government Property form permitting applicants to use MHUs as temporary
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

housing. Burden hours have decreased by 1,949 due to updated forecasting estimates received from the
FEMA RAD based on historical data from years 2007-2019.
FEMA Forms FF-104-FY-21-128 (formerly FF 009-0-3, English) and FF-104-FY-21-128-A
(formerly FF 009-0-4, Spanish), Declaration and Release – For FEMA disaster assistance eligibility
requirements to be met, a household member must be a citizen, non-citizen national or qualified alien of
the United States. FF-104-FY-21-128 (formerly FF 009-0-3, English) or FF-104-FY-21-128-A
(formerly FF 009-0-4, Spanish) is used to certify the individual’s information and eligibility.
Information gathered in this form is imbedded within FF-104-FY-21-125 (formerly FF 009-0-1Int), FF104-FY-21-125-A (formerly FF 009-0-2Int), and FF-104-FY-21-123 (formerly FF 009-0-1T), therefore
FF-104-FY-21-128 (formerly FF 009-0-3) and FF-104-FY-21-128-A (formerly FF 009-0-4) are only
utilized in circumstances when FEMA registrations are collected via FF-104-FY-21-122 (formerly FF
009-0-1) or FF-104-FY-21-122-A (formerly FF 009-0-2), Paper Application. Burden hours have
decreased by 1,640 due to updated forecasting estimates received from the FEMA RAD based on
historical data from years 2007-2019.
Request for Information (RFI) (English and Spanish) – RFI letters are currently utilized to gather
additional documentation from disaster assistance applicants to verify disaster related losses and to
prevent a duplication of benefits (i.e., receiving insurance settlement payments that fully cover the
losses and receiving the same financial assistance from FEMA). RFIs are tailored to the applicant’s
claimed loss categories (e.g., transportation, moving and storage, medical/dental, child care, etc.), and
request information such as vehicle registrations, auto mechanic receipts, and vehicle insurance policies;
itemized bills, receipts, or estimates from medical providers, written statements from medical providers
confirming injuries or illnesses are disaster-related, and medical insurance policies; itemized receipts,
bills, or estimates for moving and storage expenses and insurance settlement letters; proof of income
before and after the disaster, proof of child care expenses before and after the disaster, and proof the
child care provider is licensed. Burden hours have decreased by 62,927 due to updated forecasting
estimates received from the FEMA RAD based on historical data from years 2007-2019.
FEMA Form FF-256-FY-21-100 (English), Equity Demographics Questions – FEMA will obtain
information about the demographic characteristics of those who apply for disaster assistance grants and
will allow FEMA to assess and enforce its civil rights, nondiscrimination and equity requirements and
obligations as outlined in Federal civil rights laws such as the Civil Rights Act, Rehabilitation Act and
Stafford Act. As an example of FEMA’s requirements, Section 308 of the Robert T. Stafford Act
requires disaster assistance, including “the distribution of supplies, the processing of applications, and
other relief and assistance activities” by FEMA and recipients of FEMA financial assistance, “be
accomplished in an equitable and impartial manner, without discrimination on the grounds of race,
color, religion, nationality, sex, age, disability, English proficiency, or economic status.”
The questions will be included towards the end of a grant collection form online, through the call center,
and on paper. The data collection will use technology to search, query, or analyze information based on
the demographic categories and protected characteristics identified in civil rights laws, including the
Stafford Act.

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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.
.

The Robert T. Stafford Disaster Relief and Emergency Act, Pub. L. 93-288 provides the legal
authority for FEMA’s collection of information for disaster assistance benefits. 44 C.F.R. §206.110
implements the policy and procedures set forth in section 408 of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5174, as amended.
44 C.F.R. Part 16, Enforcement of Nondiscrimination on the Basis of [Disability] in Programs or
Activities Conducted by the Federal Emergency Management Agency,
implements Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794, and the
disability-related non-discrimination provisions set forth in §§ 308 and 309 of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act, as amended, 42
U.S.C. §§ 5151 and 5152.
DHS Directive Number 065-01, Nondiscrimination for Individuals with Disabilities in DHSConducted Programs and Activities (Non-employment) issued 9/25/2013 requires DHS Components
to provide equal opportunity for qualified individuals with
disabilities served or encountered in DHS-conducted programs and activities, including providing
any necessary modifications to afford a qualified individual with a disability full enjoyment of the
program or activity unless modifications of policies, practices, and procedures would fundamentally
alter the nature of the program, service, or activity, or result in undue financial or administrative
burdens to DHS. These laws, regulations, and policies require FEMA to provide meaningful access
to individuals with disabilities.
The Homeland Security Act of 2002, 6 U.S.C. §§ 311-321j; Reorganization Plan No. 3 of 1978, 43 Fed.
Reg. 41943; 4 U.S.C. §§ 2904 and 2906; 44 C.F.R. § 206.2(a)(27); The Personal Responsibility and
Work Opportunity Reconciliation Act of 1996, Pub. L. 104-193; the Government Performance and
Results Act of 1993, Pub. L. 103-62, as amended; Executive Order 12862, Setting Customer Service
Standards, dated September 11, 2003; Executive Order 13411, Improving Assistance for Disaster
Victims, dated August 29, 2006; and Executive Order 9397 as amended by Executive Order 13478,
Related to Federal Agency Use of Social Security Numbers, dated November 18, 2008.
FEMA requests Social Security Numbers (SSNs) pursuant to the Debt Collection Act and the Debt
Collection Improvement Act of 1996, 31 U.S.C. §§ 3711 – 3720EPub. L. 104–134, as amended; and
Internal Revenue Code of 1986, 26 U.S.C. § 6109 and 31 U.S.C. §§ 3325(d) and 7701(c)(1).

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.

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: www.DisasterAssistance.gov

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.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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.
Demographic Questions:

•

•
•
•
•

Applicant’s Demographics:
o Ethnicity (Hispanic or Latino, Neither, or Prefer not to Answer)
o Racial category (American Indian or Alaska Native, Asian, Black or African American,
Native Hawaiian or Other Pacific Islander, White, or Prefer Not to
Answer)
Gender (Female, Male, Another Identity [e.g., transgender, nonbinary, or gender
variant], or Prefer Not to Answer)
Tribal Nation enrollment status (Yes, No, or Prefer Not to Answer)
Highest Level of Formal Education (Did not complete high school, High School
Graduate/GED, Some College, Associate Degree, Bachelor’s Degree, Master’s Degree,
Doctoral Degree, or Prefer Not to Answer)
Marital Status (Never Married, Married or Living with Partner, Separated, Widowed,
Divorced, or Prefer Not to Answer)

Currently Approved Information Collected in RI:

•
•
•
•

•
•
•
•
•
•
•
•

Individual and/or household member names
Individual and/or household member relationships to the applicant
Applicant’s Citizenship Status
Disability-related accommodations or assistance the applicant may need
o Sign Language Interpreter
o CART (Communication Access Real-time Translation) (in person or remote)
o Text Message to Communicate
o Assistive Listening Device
o Braille
o Wheelchair Access
o Large Print
o Face-to-Face Assistance
o Language Other Than English
Age of household occupants
Dependent status of household occupants
Damaged dwelling address
Current mailing address
County in which the damaged occurred
Applicant’s current phone number
Applicant’s alternate phone number
Applicant’s cell phone number

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

•
•
•
•
•
•
•
•
•
•
•

Birth date of the applicant, co-applicant, and household occupants

•

Household vehicle information
o Year
o Make
o Model
o Damaged
o Insurance Information
o Childcare expenses
Emergency Needs (food, medication, durable medical equipment, gas, shelter, and/or
clothing)
Applicant or household member disability-related needs, for example:
o Mobility
o Cognitive/Developmental Disabilities/Mental Health
o Hearing or Speech
o Vision
o Self-Care
o Independent Living

•
•

Social Security Number (of the applicant and co-applicant only)
Household income of applicant, co-applicant, and adult occupants
Home insurance information
Residence type
Bank name
Bank account type
Bank account number
Applicant’s email address
Amount of damage (self-assessed) to the applicant’s home or personal property
Disaster-related expenses
o Medical
o Dental
o Funeral

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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
☐ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☒ Bank Account, Credit Card, or
other financial account number
☐ Other. Please list: Disability-related

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☒ Driver’s License/State ID
☐ Biometrics

information

g. List the specific authority to collect SSN or these other SPII elements.
The Robert T. Stafford Disaster Relief and Emergency Act, Public Law 93-288 provides the legal
authority for FEMA’s collection of information for disaster assistance benefits. 44 CFR § 206.110
implements the policy and procedures set forth in section 408 of the Robert T. Stafford Disaster Relief
and Emergency Assistance Act, 42 U.S.C. § 5174, as amended.
The Homeland Security Act of 2002, 6 U.S.C. §§ 311- 321j; Reorganization Plan No. 3 of 1978, 43
Fed. Reg. 41943; 4 U.S.C. §§ 2904 and 2906; 44 C.F.R. § 206.2(a)(27); The Personal Responsibility
and Work Opportunity Reconciliation Act of 1996, Pub. L. 104-193; the Government Performance and
Results Act of 1993, Pub. L. 103-62, as amended; Executive Order 12862, Setting Customer Service
Standards, dated September 11, 2003; Executive Order 13411, Improving Assistance for Disaster
Victims, dated August 29, 2006; and Executive Order 9397 as amended by Executive Order 13478,
Related to Federal Agency Use of Social Security Numbers, dated November 18, 2008.
FEMA requests Social Security Numbers (SSNs) pursuant to the Debt Collection Act and the Debt
Collection Improvement Act of 1996, 31 U.S.C. §§ 3711 – 3720EPub. L. 104–134, as amended; and
Internal Revenue Code of 1986, 26 U.S.C. § 6109 and 31 U.S.C. §§ 3325(d) and 7701(c)(1).

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.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

The SSN is collected to verify the applicant’s identity and prevent duplication of disaster benefits among
FEMA, federal, state, and local disaster agencies. In accordance with the
U.S. Treasury Department, the applicant’s social security number is required to issue funds to
individuals determined eligible for assistance.
Additional SPII is collected for FEMA to deposit financial assistance through electronic funds transfers
(EFT) to applicants’ bank accounts. Medical information is collected for the purpose of reimbursing
survivors for disaster-related injuries, and to replace durable medical equipment lost or damaged due to
the disaster.
Demographic data will be used to assess whether FEMA programs appear to be treating everyone the
same with respect to race, ethnicity, gender identity, marital status, or education. Any anomalies
detected can be used for FEMA to assess policies and make changes to policies and procedures to better
assist underserved communities.

i.

Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

☒ Yes. Please describe how notice is provided.
Individuals will be provided separate notices
consistent with the purpose of the information
collection. Notice is provided when the applicant
registers for assistance, and a copy of the disaster
assistance registration is mailed to the applicant which
includes the notice. Additional notice, specific to the
purpose and uses of the demographic information, is
provided prior to collection that information.

☐ No.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
National Emergency Management Information System –
Individual Assistance (NEMIS-IA) will store the data, but
will not make demographic information visible to
caseworkers or other staff

☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
NEMIS-IA

b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
FEMA manually enters data into the NEMIS-IA electronic
version of FF-104-FY-21-122 (formerly FF 009-0-1,
English) or FF-104-FY-21-122-A (formerly FF 009-0-2,
Spanish) for registrants applying for disaster assistance
telephonically or using paper versions of the forms.

☒ Automatically. Please describe.
Information is collected and uploaded into the
NEMIS-IA Registration Intake Modules via business
rules.

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
By the applicant’s name, address, social security number,
demographic identifiers (race, ethnicity, gender, marital
status, education), and email address.

☒ By a non-personal identifier. Please describe.
Each registrant is issued a Registration Identification (ID)
number

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

d. What is the records
retention
schedule(s)? Include
the records schedule
number.

Records pertaining to disaster assistance will be placed in
inactive storage two years after FEMA receives the application
and will be destroyed when they are six years and three months
old, NARA Authority N1-311-86-1, item 4C10a. DAP 8-1.

The program adheres to the disposition schedule which
e. How do you ensure
provides timeframes for records destruction and/or disposal of
that records are
relevant documents associated with the program. Disposition
disposed of or deleted
schedule: TEMPORARY. Retire to inactive storage when 2
in accordance with
years old. Destroy when 6 years 3 months old.
the retention
schedule?
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.

FEMA programs administering federal disaster relief assistance adhere to comprehensive internal
management procedures to prevent, detect, deter, report, and investigate fraud, waste, and abuse.
FEMA programs and employees proactively review FEMA’s awards of disaster assistance
payments. After the disaster assistance registration process, it may be found an applicant
potentially committed fraud and/or identity theft. FEMA may share the applicant information with
the DHS Office of the Inspector General (OIG) to assist with investigation of potential fraud
and/or identity theft.
Demographic information in the form of aggregated statistics may be provided to the Office of
Equal Rights (OER) for monitoring purposes. Individual demographic information may be provided
to OER upon receipt of applicant inquiries or OER investigation of applicant complaints.

☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.

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.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Upon receipt of the information collected during the disaster assistance registration process, FEMA
may share disaster applicant information with state governments to assist with implementation of
housing programs, to ensure applicants receive additional disaster assistance as necessary, and to
prevent a duplication of benefits.
FEMA programs administering federal disaster relief assistance adhere to comprehensive internal
management procedures to prevent, detect, deter, report, and investigate fraud, waste, and abuse.
FEMA programs and employees proactively review FEMA’s awards of disaster assistance
payments. After the disaster assistance registration process, it may be found an applicant
potentially committed fraud and/or identity theft. FEMA may share the applicant information with
the Federal Bureau of Investigations (FBI), the Department of Justice (DOJ) and/or state law
enforcement to assist with investigation of potential fraud and/or identity theft.
If the applicant receives FEMA financial assistance and it is later determined the assistance was
awarded improperly or due to the applicant providing false information, the applicant’s information
may be provided to the Department of Treasury (DOT) to recoup the previously awarded funds.
FEMA will share disaster applicant information, for applicants who exceed the Small
Business Administration (SBA) provided income threshold, to the SBA Credit Management
Systems for low-interest loan consideration. Personal information such as name, address, social
security number, assets and salary are securely transmitted from FEMA to SBA for processing.
SBA will return a status code for each application received from FEMA, reflecting their SBA
disaster loan eligibility.
FEMA has contracted with risk management vendors to provide information received from
applicants during registration intake for identity verification purposes. The vendor returns a pass/fail
result to FEMA, and assists in verifying applicant occupancy of the residence damaged by the
disaster as needed.
A Memorandum of Understanding (MOU) and Interconnects Security Agreement (ISA) between
FEMA and each participating agency defines the conditions for security and data use, from data
exchanges to the extent they are not covered by other formal arrangements or agreements between
the Parties. This agreement also covers any existing data exchanges covered in the DHS/FEMA –
REG 2 DRA SORN.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

FEMA has a Computer Matching Agreement (CMA) with the Department of Housing and Urban
Development (HUD). The purpose of the matching program is to:
• Establish or verify initial or continuing eligibility for DHS/FEMA disaster
assistance programs.
• Verify compliance with statutory or regulatory program requirements; and

•
•

Recoup payments or delinquent debts under an identified program.
Specifically, DHS/FEMA and HUD seek to ensure that individuals do not receive duplicate
or erroneous disaster assistance for the same disaster or emergency and/or housing benefits
from either agency.

Legal authorities
This agreement is executed in compliance with Privacy Act of 1974 (5 U.S.C.552a), as amended.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act P.L. 93-288, (42 U.S.C.
5121, 42 U.S.C. 5155, 42 U.S.C. 5174); 44 C.F.R. 206.2(a)(27), 206.110(e),
206.115(f), and 206.44.
The Debt Collection Improvement Act of 1996, 31 U.S.C. 3325(d) and 7701(c)(1), as amended.
HUD regulations 24 CFR 5.233, Community Development Block Grant (CBDG) program as
required by Title I of the Housing and Community Development Act of 1974, 12
U.S.C. 1706e, as amended by the Community Development Block Grant-Disaster Recovery
(CDBG-DR) Appropriations Acts (Pub. L. 113-2), and by the notices published in Federal Register
that govern these CDBG-DR Appropriations Acts.
No. Information on this form is not shared outside of the collecting office.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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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:

Everson (Randy) Hull

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

December 28, 2022

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 28, 2022
☒ 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.
PIA:
DHS/FEMA—026 Operational Data Store and Enterprise Data Warehouse (August
2018).
DHS/FEMA—049 Individual Assistance (IA) Program (January 2018).
SORN:
DHS/FEMA—008 Disaster Recovery Assistance Files (February 10, 2022).

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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:

Laquitta Murray (Schuntel Reddock)

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Click here to enter text.
January 18, 2023
January 18, 2026

DESIGNATION
Privacy Sensitive IC or
Form:
Determination:

Yes If “no” PTA adjudication is complete.
☐ 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:

Choose an item.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
e(3) statement update is required.
Statement:
e(3) statement updated statement submitted and approved.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
If covered by existing PIA, please list: DHS/FEMA-026 Operational Data
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Store and Enterprise Data Warehouse; DHS/FEMA-049 Individual
Assistance (IA) Program
If a PIA update is required, please list: Click here to enter text.
System covered by existing SORN
If covered by existing SORN, please list: DHS/FEMA-008 Disaster Recovery
Assistance Files, February 10, 2022, 87 FR 7852, DHS/FEMA-017
Individuals and Households Program Equity Analysis Records System of
Records, August 3, 2022, 87 FR 47439
If a SORN update is required, please list:
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
FEMA is submitting this form PTA to document Streamline Registration Intake (RI) process
information collection. The purpose of this system is to provides financial assistance and,
direct assistance to eligible individuals and households who, as a direct result of a major
disaster or emergency, have uninsured or under-insured necessary expenses and serious
needs, and are unable to meet such expenses or needs through other means.
SORN:

Using the forms Streamline Registration Intake forms, applicants for disaster assistance
can select the type of assistance they require and only answer questions directly related to
the specific types of assistance they need.
DHS PRIV agrees this form is privacy sensitive, requiring both PIA and SORN coverage. PIA
coverage is provided by DHS/FEMA-049 Individual Assistance (IA) Program, which covers
the collection, use, maintenance, retrieval, and dissemination of personally identifiable
information (PII) of applicants for the purpose of implementing the FEMA IA programs.
Additional PIA coverage is provided by DHS/FEMA-026 Operational Data Store and
Enterprise Data Warehouse, which covers the collection, use, maintenance, retrieval, and
dissemination of information pulled from the source systems.
SORN coverage is required because information is retrieved by a unique identifier. SORN
coverage is provided by DHS/FEMA 008 Disaster Recovery Assistance Files, which covers
FEMA-approved Weapons of Mass Destruction (WMDs) training and information.
Additional SORN coverage is provided by DHS/FEMA-017 Individuals and Households
Program Equity Analysis, which covers the collection and maintenance of records on
applicants for disaster assistance programs.

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