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pdfThe Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 1 of 8
PRIVACY THRESHOLD ANALYSIS (PTA)
This form is used to determine whether
a Privacy Impact Assessment is required.
Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under
the E‐Government Act of 2002 and the Homeland Security Act of 2002.
Please complete this form and send it to your component Privacy Office. If you do not have a component
Privacy Office, please send the PTA to the DHS Privacy Office:
Rebecca J. Richards
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703‐235‐0780
PIA@dhs.gov
Upon receipt, the DHS Privacy Office will review this form. If a PIA is required, the DHS Privacy Office
will send you a copy of the Official Privacy Impact Assessment Guide and accompanying Template to
complete and return.
A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy,
on DHSOnline and directly from the DHS Privacy Office via email: pia@dhs.gov, phone: 703‐235‐0780.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 2 of 8
PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: August 1, 2009
NAME of Project: FEMA FY 2009 Trucking Security Program (TSP)
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Paul Belkin
Email for Project Manager: Paul.Belkin@fema.gov
Phone number for Project Manager: 202‐786‐9771
TYPE of Project:
Information Technology and/or System
A Notice of Proposed Rule Making or a Final Rule.
Other: FEMA is seeking OMB clearance for TSP
The E‐Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note, for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed
for potential privacy impact.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 8
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
In partnership with the Transportation Security Administration (TSA), FEMA has the lead
for designing and operating the administrative mechanisms for the FY 2009 Trucking
Security Program (TSP). The purpose of the TSP is primarily focused on the purchase and
installation or enhancement of equipment and systems related to tractor and trailer tracking
systems. The TSP provides funding to develop a system for DHS to monitor, collect, and
analyze tracking information; and develop plans to improve the effectiveness of
transportation and distribution of supplies and commodities during catastrophic events. The
TSP targets Tier I (11 or more tractors) and Tier II (10 or less tractors) trucking companies.
A national review panel of subject matter experts from federal agencies reviews the proposals
of those applicants that have complied with all administrative grant requirements.
Applications are evaluated based on feasibility, timelines, and sustainability. FEMA notifies
the State Administrative Agencies (SAAs) of trucking projects funded under this grant
program.
Additional
details
on
the
TSP
can
be
found
at
http://www.fema.gov/pdf/government/grant/tsp/fy09_tsp_guidance.pdf.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: 2005
Date last updated: August 1, 2009
FEMA is seeking Office of Management and Budget (OMB) clearance for the TSP.
3.
Could the project relate in any way to an individual? 1
No. Please skip ahead to the next question.
Yes. Please provide a general description, below.
The type of information that may be collected and/or retained are the names of
organizational Point(s) of Contact, organizational address, organizational email addresses,
1
Projects can relate to individuals in a number of ways. For example, a project may include a camera for
the purpose of watching a physical location. Individuals may walk past the camera and images of those
individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a
project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an
individual received chemotherapy.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 8
and additional contact information. No Personally Identifiable Information (PII) is collected
outside of the organizational information.
4.
Do you collect, process, or retain information on: (Please check all that apply)
DHS Employees
Contractors working on behalf of DHS
The Public
The System does not contain any such information.
5.
Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:
6.
What information about individuals could be collected, generated or retained?
TSP awards are made by organization, not by an individual. The only eligible
applicants for TSP funds are those who have a current security plan subject to Title
49 CFR 172.800 Transport Tier I Commodities as defined by TSA and consist of 11 or
more tractors (Tier I) or consist of 10 or less tractors (Tier II). TSP has five standard
federal grant forms: Application for Federal Assistance SF‐424, Disclosure of
Lobbying Activities, Budget Information ‐ Non‐Construction Programs SF424A‐V10,
Assurances ‐ Non‐Construction Programs SF424B, and Financial Status Report
SF269A. However, each preparedness grant program varies and has a different set of
requirements. Consequently, FEMA collects and/or retains applicant information
including:
Type of Submission;
Type of Application;
Date Received;
Applicant Identifier;
Federal Entity Identifier;
Federal Award Identifier;
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 8
7.
Date Received by State;
State Application Identifier;
Names of organizational Point(s) of Contact;
Employer Identification Number (EIN) and Dun & Bradstreet (DUNS)
numbers;
Organizational address;
Organizational email addresses;
Department Name;
Division Name;
Organizational telephone and fax number;
Organizational Investment Justification;
Name of Federal Agency;
Catalog of Federal Domestic Assistance (CFDA) Number;
CFDA Title and;
Funding Opportunity Number;
Competition Identification Number; and
Areas Affected by Project
If this project is a technology/system, does it relate solely to infrastructure? [For example, is
the system a Local Area Network (LAN) or Wide Area Network (WAN)]?
No. Please continue to the next question.
Yes. Is there a log kept of communication traffic?
No. Please continue to the next question.
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header
Payload Please describe the data that is logged.
8.
Can the system be accessed remotely?
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 6 of 8
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
No. Applicants provide application data upon submitting their proposals to FEMA
via grants.gov, which is accessible via Internet.
Yes.
9.
Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes. PII, as it relates to an individualʹs employment by an eligible grant entity, is transported
outside the LAN (via Internet) and transmitted to grants.gov. FEMA accesses grants.gov to
download application data, which includes PII, such as an organizationʹs Point of Contact (POC)
name, organizational POCʹs email address, and organizational POCʹs telephone number .
10.
Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 3 ?
No
Yes. Please list:
11.
Are there regular (ie. periodic, recurring, etc.) data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation 4 ?
Yes.
No.
2
Personally Identifiable Information is information that can identify a person. This includes; name, address, phone
number, social security number, as well as health information or a physical description.
3
PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes.
Often, these systems are listed as “interconnected systems” in TAFISMA.
4
This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 8
12.
Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:
Integrity:
Availability:
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 8 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: September 17, 2009
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System
National Security System
Legacy System
HR System
Rule
Other:
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: Grant Management Programs
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/FEMA‐004
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
File Type | application/pdf |
File Title | DHS PRIVACY OFFICE |
Author | pia |
File Modified | 2009-09-17 |
File Created | 2009-09-17 |