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:

Next Generation Volcano Hazards Assessment
(NGVHA)

B. Bureau or Office:

U.S. Geological Survey

C. Program or Office:

Volcano Hazards Program
USGS California Volcano Observatory

D. Project/Program Manager or System
Owner:

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

Name: Jessica L. Ball
Title: Research Geologist
Phone: 650-439-2597
E-mail: [email protected]

E. Routing Information:

_X__ New PTA

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.

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.

___ Updated PTA
Date of Submission:

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

Privacy Threshold Analysis

Section 2. Project, Program or System Summary
Question

Response

A. General description of the project, program The Next Generation Volcano Hazards Assessment
or system. Please provide a description of the project (NGVHA) project, currently funded within the USGS
or program, including any background information to
Volcano Hazards Program (VHP), aims to produce a
help understand the project, program or system. If this next-generation of comprehensive volcanic hazard
is an updated PTA, please describe the changes that
assessments (VHAs) for high-priority U.S. volcanoes.
triggered the update to this PTA. Please also indicate
NGVHA is a framework for creating up-to-date,
if the PTA is being updated as part of its annual
actionable volcano hazards assessments for high-priority
review.
U.S. volcanoes. These assessments are based on
multidisciplinary research and modeling and incorporate
the best practices of user-centered design. Because the
usefulness and usability of USGS volcano hazards
assessments depend on input from the audiences for
which they are produced, it is necessary to incorporate
user needs elicitation into the hazard assessment
creation process.
The systemic collection of this information through
open-ended ethnographic data collection methods (semistructured interviews, workshops, surveys) will result in
a significant improvement of both the volcano hazard
products and associated services provided by the VHP.
Most of these methods can be completed in part or fully
remotely (via phone or video calls or online meetings).
In addition, broader stakeholder and community surveys
can be conducted via virtual methods (online surveys,
social media) in order to reduce the paperwork burden
and more efficiently analyze data. The USGS VHP
already has a strong presence on social media and web,
which enables us to reach a wide audience without
placing an undue burden on any particular group.
B. What is the technology or format used for
the Project, Program or System?

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.

___ IT System
___ New Project or Program
___ Website
_X__ Web Form, Survey or Information Collection
___ Third-Party Website
_X__ Social Media Application
___ SharePoint
___ Mobile Application
___ Closed Circuit Television (CCTV)
_X__ Paper-based Collection

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

Privacy Threshold Analysis

_X__ Other: Direct interviews, workshops, or listening
sessions/focus groups recorded and transcribed.

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

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.

_X__ Yes: In-person or remote data collection will be

completed using semi-structured interviews, participatory
workshops (e.g. for iterative design purposes), and participant
observation. These open-ended ethnographic data collection
methods will allow for deep data collection, to include
nuances in experiences across different demographics. Most
of these methods can be completed in part or fully remotely
(via phone or video calls or online meetings). In addition,
broader stakeholder and community surveys can be
conducted either through paper forms or via virtual methods
(online surveys sent via email, social media).

___ No
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.

_X__ Yes: OMB Control Number 1028-NEW. A 60-day

FRN has already been completed and final documentation is
being prepared for a 30-day FRN.

___ No

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

Privacy Threshold Analysis

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

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.

___ Contractors
__X_ Members of the public
__X_ Other: State, local officials, emergency managers.
___ This project, program or system does not collect,
maintain or process PII

We collect the name, email, and phone number of the
reporting party in order to have this information in case
we have follow-up questions. No PII will be published or
otherwise disseminated.
Interviews will be recorded on a small digital audio
recorder kept in possession of the interviewer while there
are files saved on it or, when in-person is not an option,
on Teams (video & audio). Recordings will be uploaded
(audio recorder) or downloaded (Teams) onto a
government-owned, password-protected computer and
stored locally as well as synched in OneDrive cloud
space within the password-protected USGS account(s) of
research team member(s) for backup. Files will be names
with codes rather than interviewee PII. Transcripts will
be named and stored in the same manner, with the same
codes and in the same two password-protected spaces.
Interview files will be kept after transcription in case
researcher(s) need to verify quotes or listen to the audio
for context (e.g., through intonation). Recordings will be
deleted at the end of the project or after five years,
whichever comes first.
__X_ Yes: Individuals will be assigned a unique code
which is listed with their PII in a spreadsheet that is
password-protected and accessible only to the research
team. This code is then used for all documents related to
that individual.
___ No

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

Privacy Threshold Analysis

Question

Response

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

___ Yes

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__ No

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

___ Yes

F. Does this Project, Program or System
receive or share PII with any other internal
DOI programs or systems?

___ Yes

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

___ Yes

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

___ Yes

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.

Indicate whether PII will be shared with or from
internal organizations within DOI.

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 maintain

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_ No

__X_ No

__X_ No

__X_ No (no external sharing)

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

Privacy Threshold Analysis

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.

Bureau Associate Privacy Officer Comments:

PTA is sufficient at this time.

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.

The NGVHA project encompasses numerous parallel
research efforts focused on establishing a model for
producing consistent and comprehensive volcanic
hazards assessments for high-priority U.S. volcanoes. In
order to update outdated assessments with the latest
research and techniques, the NGVHA project needs
usability and user needs investigations that will support
production of hazard- and risk-reduction products efforts
with interagency partners, Sovereign Tribal Nations, and
communities potentially affected by eruptions. (20-16.
Exploring user needs and community engagement for
next-generational volcano products, maps, and tools |
U.S. Geological Survey (usgs.gov)).
PII collected is limited to contact information for
participants. Researchers may also use audio recording
devices to conduct oral interviews with participants.
There is a risk that participants may provide unsolicited
personal information in their responses. As such,
researchers must ensure extraneous PII/personal
information is protected from unauthorized disclosure.
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U.S. Department of the Interior

Associate Privacy Officer Name:
Bureau/Office:
Date:

NGVHA

Privacy Threshold Analysis

Records collected are not retrieved by use of any
personal identifiers, hence they are not subject to the
provisions of the Privacy Act of 1974. Overall, there is a
low risk of harm to the individuals in the event of
disclosure. The System Owner must ensure access
controls are in place to protect the PII collected. Access
to PII should be restricted to personnel who require
access in the performance of official duties. If PII data is
lost or compromised, it must be reported in accordance
with procedures in the DOI Privacy Breach Response
Plan (Section 5.0 – Reporting a Suspected or Confirmed
Breach of PII. If changes or new collections of PII are
initiated, the information collection must be reassessed to
ensure the records remain in compliance with Federal
privacy regulations and Departmental policies.
signed by COZENJA BERRY
COZENJA BERRY Digitally
Date: 2024.05.15 13:29:54 -04'00'

United States Geological Survey (USGS
May 15, 2024
DOI Privacy Office Comments

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