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:

1670-0046

Form Title:

SAFECOM Membership Questionnaire

Component:

Cybersecurity and
Infrastructure Security
Agency (CISA)

Office:

Emergency
Communications
Division (ECD)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
SAFECOM Membership Questionnaire
OMB Control
Number:
Collection status:
Name:
Office:
Phone:
Name:

1670-0046

New Collection

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

July 31, 2025
July 7, 2020

PROJECT OR PROGRAM MANAGER
Georgia Anagnostopoulos
ECD
Title:
PRA Manager
240-409-4798
Email:
georgia.anagnostopoulos@a
ssociates.cisa.dhs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Benjamin Thomsen

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

Office:

Phone:

Office of the Chief
Title:
IT Cybersecurity Program
Information Officer (OCIO)
Manager
202-254-7179
Email:
[email protected]
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.
PACT is submitting this PTA in line with the three-year expiration cycle and to
document updates to the SAFECOM Membership Questionnaire that have occurred
since its initial PTA in July 2020. The only changes to note at this time are to the
project manager and information collection contacts.
Through collaboration with emergency responders and elected officials across all
levels of government, the Assuring a Safer America Through Effective Public Safety
Communications (SAFECOM) program works to improve emergency response
providers’ inter- jurisdictional and interdisciplinary emergency communications
interoperability across local, regional, tribal, state, territorial, international
borders, and with federal government entities. SAFECOM works with existing
federal communications programs and key emergency response stakeholders to
address the need to develop better technologies and processes for the
coordination of existing communications systems and future networks.
Through these partnerships, SAFECOM has created key documents such as the
Interoperability Continuum, the Statement of Requirements (SoR) for baseline
communications and interoperability standards, the Statewide Communication
Interoperability Plan (SCIP) Methodology, and the National Emergency
Communications Plan (NECP) to assist emergency responders nationwide with
improving communications and interoperability.
The purpose of the SAFECOM Membership Questionnaire is a nationwide data
collection effort to obtain actionable and critical data that drives our nation’s
emergency communication policies, programs, and funding. SAFECOM 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

leverage the collected data to identify individuals with specific expertise and
inform development of the program’s strategic priorities.
The questionnaire, submitted bi-annually or upon new membership to SAFECOM,
is designed to identify membership gaps, obtain updated information on
SAFECOM’s membership body (e.g., public safety communications experience,
accomplishments, acquired skills/certifications, etc.), update SAFECOM resources
in order to be in line with the current state of the nation’s emergency
communications.
SAFECOM seeks responses from emergency response provider organizations at the
federal, state, local, and territory levels of government, as well as Tribal Nations
with:
•
A public safety-related mission in the following four disciplines: Law
Enforcement, Fire & Rescue, Emergency Medical Services (EMS), and Public Safety
Answering Points (PSAPs)/Public Safety Communications Centers (PSCCs).
•
Users of public safety communications technology during day-to-day and
out-of- the-ordinary situations.
The personal contact information collected in section one of the questionnaire will
be inputted into the SAFECOM Internal Membership Profile Tracker, a database
directory housed on SAFECOM’s dedicated space on HSIN accessible to all
SAFECOM members in order to facilitate communication and collaboration
between members.
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.
Public Law 109-296, Title VI, §671(b), Title XVIII, §1801(c)(2)

2. Describe the IC/Form

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

a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

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.)

d. How do individuals
complete the form? Check
all that apply.

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☐ Non-U.S. Persons
☒ DHS Employees/Contractors
CISA
☒ 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/contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.

☒ Paper.
☒ Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

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 individual 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.
, Full name, email, phone number, city and state of residence, biography (user will
upload a copy of their bio/resume listing their experience and accomplishments.
Upload can be in PDF or docx format), LinkedIn contact information, tenure
(active/retired). Social Media platforms used?
The questionnaire itself is strictly voluntary. Responses nor membership into
SAFECOM is required. Respondents may submit responses to any of the data
elements for the use of SAFECOM to use in its database of public safety experience.
Individuals may also voluntarily provide memberships, national associations,
organizations, special intertest groups, education, volunteer experience, etc. Such
voluntary responses will allow SAFECOM to update its database in with accurate
contact information and capabilities of emergency response providers.

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
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:

g. List the specific authority to collect SSN or these other SPII elements.
N/A

h. How will the SSN and SPII information be used? What is the purpose of the
collection?
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

i.

Is SSN necessary to carry out the functions of this form and/or fulfill
requirements of the information collection? Note: even if you are properly
authorized to collect SSNs, you are required to use an alternative identifier. If
there are technological, legal, or regulatory limitations to eliminating the SSN,
privacy-enhancing alternatives should be taken, such as truncating the SSN.
Click here to enter text.
j.

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.
Notice is provided to individuals as per the Privacy
Act Statement on the SAFECOM Questionnaire
form itself and with the PRA Burden Statement.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
All paper submissions will be stored in a locked file
completed IC/forms?
cabinet. Paper submissions will be used with
members cannot or do not have adequate access to
the electronic questionnaire. Paper submissions will
be transcribed by CISA/ECD into the SAFECOM
databased located in HSIN, and once inputted the
paper submission will be shredded securely by
CISA/ECD.
☒ Electronic. Please describe the IT system that will
store the data from the form.
All electronic submissions will be stored on
SAFECOM’s dedicated space on the Homeland
Security Information Network (HSIN) accessed only
by SAFECOM members.

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

☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.

☐ Manually (data elements manually entered). Please
describe.
Click here to enter text.
☒ Automatically. Please describe.
The Questionnaire is a fillable PDF. All submissions
will be uploaded and stored on the Homeland
Security Information Network (HSIN).

c. How would a user
☒ By a unique identifier. 2 Please describe. If
search the
information is retrieved by personal identifier, please
information
submit a Privacy Act Statement with this PTA.
submitted on the
Search by first and/or last name
forms, i.e., how is the
☒ By a non-personal identifier. Please describe.
information
City and State of location
retrieved?
d. What is the records
The information collected by SAFECOM will be
retention
retained in accordance with NARA General Records
schedule(s)? Include
Schedule (GRS) GRS 5.3, Item 020 (DAA-GRS-20160004-0002) - Employee emergency contact
the records schedule
information.
number.
e. How do you ensure
In accordance with the records schedule DAA-GRSthat records are
2016-0004-0002, records are to be destroyed when
disposed of or deleted
superseded or obsolete, or upon separation of the
in accordance with
individual from SAFECOM membership.
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?
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

☒ Yes, information is shared with other DHS components or offices. Please describe.
Information derived from the SAFECOM Questionnaire, is available in the
SAFECOM Internal Membership Profile Tracker, to all approved CISA users of
HSIN or by request via email at [email protected].

☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
The information on the SAFECOM Internal Membership Profile Tracker, is also
available to non-DHS SAFECOM Members with HSIN access or by request via email at
[email protected].
☐ No. Information on this form is not shared outside of the collecting office.

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:

Date submitted to Component Privacy
Office:
Concurrence from other Components
involved (if applicable):
Date submitted to DHS Privacy Office:
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.)

Jacob Curry
December 7, 2023
Click here to enter text.
December 8, 2023

☒ 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.
The CISA Office of Privacy, Access, Civil Liberties and Transparency (PACT) is
submitting this PTA for the SAFECOM Membership Questionnaire, in order to
document the non-substantive changes that have occurred since the initial 2020 PTA
and renew the compliance cycle. The questionnaire is a nationwide data collection
effort to obtain actionable and critical data that drives our nation’s emergency
communication policies, programs, and funding. SAFECOM will leverage the collected
data to update the membership body as well as identify gaps and inform
development of the program’s strategic priorities.
PACT recommends that the SAFECOM Membership Questionnaire is privacy
sensitive, requiring PIA coverage due to the collection of PII. SORN coverage is also
required because the data collected can be retrieved through the use of a unique
identifier.

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

PACT recommends that PIA coverage be provided by DHS/ALL/PIA-006 DHS General
Contacts List.
PACT recommends that SORN coverage be provided by DHS/ALL-002 Department of
Homeland Security (DHS) Mailing and other Lists.

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Brian Pochatila

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date
DHS Privacy Office Approver (if
applicable):

0016024
January 24, 2024
January 24, 2027
Riley Dean

DESIGNATION

Privacy Sensitive IC or
Form:
Determination:

Privacy Threshold Analysis – IC/Form

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.
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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(3) statement currently accurate.
PAS submitted and approved.
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
If covered by existing PIA, please list: DHS/ALL/PIA-006 DHS General
Contacts List; DHS/ALL/PIA-061 HSIN 3.0 Shared Spaces On The
Sensitive But Unclassified Network; DHS/ALL/PIA-069 DHS Surveys,
Interviews, and Focus Groups
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/ALL-002 Department of
Homeland Security (DHS) Mailing and Other Lists System, November 25,
2008, 73 FR 71659
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
Privacy Act
Statement:
System PTA:

CISA is submitting this PTA renewal for the SAFECOM Membership Questionnaire, which is
a nationwide data collection effort to obtain actionable and critical data that drives the
nation’s emergency communication policies, programs, and funding. SAFECOM will
leverage the collected data to update the membership body as well as identify gaps and
inform development of the program’s strategic priorities. The only changes to note at
this time are to the project manager and information collection contacts and the
questionnaire has been updated to remove for individuals to submit headshot
photos.
The questionnaire collects personally identifiable information of personal contact
information that will be inputted into the SAFECOM’s Internal Membership Profile Tracker
and SAFECOM’s directory on HSIN. The survey information is only deleted when business
use ceases, so if a person is no longer a member of SAFECOM then their information will be
deleted.
The DHS Privacy Office finds that this questionnaire is privacy sensitive requiring PIA and
SORN coverage. PIA coverage is provided by:
• DHS/ALL/PIA-006 DHS General Contacts List collects a minimal amount of contact
information in order to distribute information and perform various other
administrative tasks.

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

•

DHS/ALL/PIA-061 HSIN 3.0 Shared Spaces On The Sensitive But Unclassified
Network enables information sharing on HSIN.
• DHS/ALL/PIA-069 DHS Surveys, Interviews, and Focus Groups permits DHS and its
Components to periodically solicit voluntary feedback from its employees,
contractors, external stakeholders, and the general public through the use of
surveys, interviews, and focus groups to improve DHS services and operations.
SORN coverage is provided By DHS/ALL-002 DHS Mailing and Other Lists System, which
maintains lists of individuals who are members.

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