Draft Privacy Impact Assessment

PRIVACY IMPACT ASSESSMENT (PIA)
PRESCRIBING AUTHORITY: DoD Instruction 5400.16, "DoD Privacy Impact Assessment (PIA) Guidance". Complete this form for Department of Defense
(DoD) information systems or electronic collections of information (referred to as an "electronic collection" for the purpose of this form) that collect, maintain, use,
and/or disseminate personally identifiable information (PII) about members of the public, Federal employees, contractors, or foreign nationals employed at U.S.
military facilities internationally. In the case where no PII is collected, the PIA will serve as a conclusive determination that privacy requirements do not apply to
system.
1. DOD INFORMATION SYSTEM/ELECTRONIC COLLECTION NAME:

Homeowners Assistance Program Management Information System (HAPMIS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

United States Army
U.S. Army Corps of Engineers
SECTION 1: PII DESCRIPTION SUMMARY (FOR PUBLIC RELEASE)
a. The PII is: (Check one. Note: Federal contractors, military family members, and foreign nationals are included in general public.)
From members of the general public

From Federal employees

from both members of the general public and Federal employees

Not Collected (if checked proceed to Section 4)

b. The PII is in a: (Check one.)
New DoD Information System

New Electronic Collection

Existing DoD Information System

Existing Electronic Collection

Significantly Modified DoD Information System
c. Describe the purpose of this DoD information system or electronic collection and describe the types of personal information about individuals
collected in the system.

HAPMIS is the automated system that supports the Homeowners Assistance Program (HAP) and serves as the official system of record for
the HAP. HAPMIS is an automated database for the following: HAP applicants; benefits applied for and received; budget plans; means of
calculating settlements; and analytical tools and reports for projection and quality control.
Personally Identifiable Information (PII) is collected from each HAP applicant and stored in HAPMIS, to include the applicant’s full name;
Taxpayer Identification Number (TIN) (i.e., Social Security Number (SSN) or Employer Identification Number (EIN)); grade/rank; mailing
address (street, city, state, zip code); employment information (Branch of Military Service, military unit, retirement system, starting and
ending dates, nature of separation,); death of service member or civilian employee information; home and work telephone numbers; personal
and work email addresses; spouses name, address, contact information. HAPMIS may also collect PII information to identify the impact
from the market change, eligibility, and entitlement to specific program benefits (ref: ER 4-5-1-12).
d. Why is the PII collected and/or what is the intended use of the PII? (e.g., verification, identification, authentication, data matching, mission-related use,
administrative use)

The HAP provides financial relief to eligible Service Member and civilian employee homeowners when their homes lose value because of a
base closure or realignment announcement, and to wounded, injured, and ill members of the Armed Forces, surviving spouses of fallen
warriors, and wounded, injured, and ill DoD civilian homeowners reassigned in furtherance of medical treatment or rehabilitation or due to
medical retirement in connection with their disability. Application for benefits under the HAP program is made using Department of
Defense (DD) Form 1607, which requests the applicant’s PII for data entry into HAPMIS including the applicant’s TIN or EIN. HAPMIS
data includes PII for HAP applicants as described under item 10 above; benefits applied for and received by applicant; budget plans; the
means of calculating settlements; and analytical tools and reports for benefit and budget/cost projection and quality control. HAP recipients
are required to pay taxes on portions of their benefits and reimbursements. The Internal Revenue Service (IRS) has the authority under 26
U.S.C. 6109 to require agencies that provide taxable benefits to collect SSNs or EINs from the corresponding taxpayers. USACE must
provide the name and corresponding SSN or EIN to the IRS, and must withhold tax payments and issue Forms W-2 and 1099 to the HAP
recipients. These actions require maintaining and reporting PII including SSNs/EINs.
e. Do individuals have the opportunity to object to the collection of their PII?

Yes

No

(1) If "Yes," describe the method by which individuals can object to the collection of PII.
(2) If "No," state the reason why individuals cannot object to the collection of PII.

DD Form 1607 Privacy Act Statement regarding disclosure of requested information is voluntary; however, failure to furnish requested
information may result in denial of benefits provided under law. If the DD Form 1607 does not provide all of the information required to
process an application, the applicant may be requested to provide supplemental information (ref: ER 405-1-12).
f. Do individuals have the opportunity to consent to the specific uses of their PII?

DD FORM 2930, FEB 2025

Yes

PREVIOUS EDITION IS OBSOLETE.

No
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(1) If "Yes," describe the method by which individuals can give or withhold their consent.
(2) If "No," state the reason why individuals cannot give or withhold their consent.

An individual grants consent through acknowledgment, completion, signature and submission of DD Form 1607 to the USACE HAP office.
Failure to furnish requested information will hinder verification of employment and homeowner information, potentially resulting in either a
delay or denial of HAP benefits.
g. When an individual is asked to provide PII, a Privacy Act Statement (PAS) and/or a Privacy Advisory must be provided. (Check as appropriate and
provide the actual wording.)
Privacy Act Statement

Privacy Advisory

Not Applicable

In addition to those disclosures generally permitted under 5 U.S.C. 552a(b) of the Privacy Act, these records or information contained
therein may specifically be disclosed outside the DoD as a routine use pursuant to 5 U.S.C. 552a(b)(3) including the Department of Housing
and Urban Development when assuming custody of acquired homes, to manage and dispose of such properties on behalf of the Secretary of
Defense; Department of Veterans Affairs in accepting subsequent purchaser in private sales when property is encumbered by a mortgage
loan guaranteed or insured by them; Department of Justice to review final title and deeds of conveyance to the Government for properties
acquired under the program, pursuant to their responsibilities under Public Law 91-393; and the Internal Revenue Service to determine tax
liability for sale of property to the Government.
h. With whom will the PII be shared through data/system exchange, both within your DoD Component and outside your Component?
(Check all that apply)
Within the DoD Component

Specify.

USACE

Other DoD Components (i.e. Army, Navy, Air Force)

Specify.

PII is redacted from appeals prior to forward to HQDA/OSD

Other Federal Agencies (i.e. Veteran’s Affairs, Energy, State)

TINs/EINs will be provided to the IRS and to the Federal
Reserve (in the case of a federal civilian payout) for the
administration of all pertinent tax laws, as all HAPMIS
Specify.
financial transactions made on behalf of HAP beneficiaries
may incur potential tax and Federal Insurance Contributions
Act (FICA) liabilities.

State and Local Agencies

Specify.

Contractor (Name of contractor and describe the language in
the contract that safeguards PII. Include whether FAR privacy
clauses, i.e., 52.224-1, Privacy Act Notification, 52.224-2,
Privacy Act, and FAR 39.105 are included in the contract.)

Specify.

Other (e.g., commercial providers, colleges).

Specify.

i. Source of the PII collected is: (Check all that apply and list all information systems if applicable)
Individuals

Databases

Existing DoD Information Systems

Commercial Systems

Other Federal Information Systems

j. How will the information be collected? (Check all that apply and list all Official Form Numbers if applicable)
E-mail

Official Form (Enter Form Number(s) in the box below)

In-Person Contact

Paper

Fax

Telephone Interview

Information Sharing - System to System

Website/E-Form

Other (If Other, enter the information in the box below)

DD1607 - Application for DoD Homeowners Assistance Program
k. Does this DoD Information system or electronic collection require a Privacy Act System of Records Notice (SORN)?
A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens or lawful permanent U.S. residents that
is retrieved by name or other unique identifier. PIA and Privacy Act SORN information must be consistent.
Yes

No

DD FORM 2930, FEB 2025

PREVIOUS EDITION IS OBSOLETE.

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If "Yes," enter SORN System Identifier

A0405-10q CE

SORN Identifier, not the Federal Register (FR) Citation. Consult the DoD Component Privacy Office for additional information or http://dpcld.defense.gov/
Privacy/SORNs/
or
If a SORN has not yet been published in the Federal Register, enter date of submission for approval to Defense Privacy, Civil Liberties, and Transparency
Division (DPCLTD). Consult the DoD Component Privacy Office for this date.
If "No," explain why the SORN is not required in accordance with DoD Regulation 5400.11-R: Department of Defense Privacy Program.

Pending review of modified SORN, submitted March 2024

l. What is the National Archives and Records Administration (NARA) approved, pending or general records schedule (GRS) disposition authority
for the system or for the records maintained in the system?
(1) NARA Job Number or General Records Schedule Authority.
(2) If pending, provide the date the SF-115 was submitted to NARA.

(3) Retention Instructions.

Case files are destroyed 10 years after final action or decision on appeals, as applicable; Homeowner assistance progress report files are
destroyed after case closed or until no longer needed for business but not longer than 6 years after case closed then destroyed and;
supervisory files are destroyed when no longer required for current operations or 1 year after case closed, then destroyed.
m. What is the authority to collect information? A Federal law or Executive Order must authorize the collection and maintenance of a system of
records. For PII not collected or maintained in a system of records, the collection or maintenance of the PII must be necessary to discharge the
requirements of a statue or Executive Order.
(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act SORN should be similar.
(2) If a SORN does not apply, cite the authority for this DoD information system or electronic collection to collect, use, maintain and/or disseminate PII.
(If multiple authorities are cited, provide all that apply).
(a) Cite the specific provisions of the statute and/or EO that authorizes the operation of the system and the collection of PII.
(b) If direct statutory authority or an Executive Order does not exist, indirect statutory authority may be cited if the authority requires the
operation or administration of a program, the execution of which will require the collection and maintenance of a system of records.
(c) If direct or indirect authority does not exist, DoD Components can use their general statutory grants of authority (“internal housekeeping”) as
the primary authority. The requirement, directive, or instruction implementing the statute within the DoD Component must be identified.

DoD Directive 4165.50E, “Homeowners Assistance Program (HAP)”; Program (HAP)”
Section 1013 of Public Law 89-754, “Demonstration Cities and Metropolitan Development Act of 1966,” as amended (80 Stat. 1255, 1290)
(80 Stat. 1255, 1290)
The American Recovery and Reinvestment Act of 2009 (ARRA)
32 CFR Part 239, Homeowners Assistance Program – Application Processing, November 16, 2010
Executive Order (EO) 9397, Numbering System for Federal Accounts Relating to Individual Persons
26 U.S.C. 6109, Identifying Numbers
DTM 07-015-USD, Guidance on the Use of the SSN by the Department of Defense
Army Regulation (AR) 405-10, Acquisition of Real Property and Interests
Army Regulation (AR) 405-16, Homeowners Assistance Program
USACE Engineering Regulation (ER) 405-1-12, Real Estate Handbook
n. Does this DoD information system or electronic collection have an active and approved Office of Management and Budget (OMB) Control
Number?
Contact the Component Information Management Control Officer or DoD Clearance Officer for this information. This number indicates OMB approval to
collect data from 10 or more members of the public in a 12-month period regardless of form or format.
Yes

No

Pending

(1) If "Yes," list all applicable OMB Control Numbers, collection titles, and expiration dates.
(2) If "No," explain why OMB approval is not required in accordance with DoD Manual 8910.01, Volume 2, " DoD Information Collections Manual:
Procedures for DoD Public Information Collections.”
(3) If "Pending," provide the date for the 60 and/or 30 day notice and the Federal Register citation.

OMB No. 0704-0463
DD FORM 2930, FEB 2025

PREVIOUS EDITION IS OBSOLETE.

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Expiration 04/30/2025

DD FORM 2930, FEB 2025

PREVIOUS EDITION IS OBSOLETE.

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