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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: April 25, 2008
Page 1 of 8
PRIVACY THRESHOLD ANALYSIS (PTA)
CONTACT LISTS
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 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
Fax: 703‐235‐0442
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,
and fax: 703‐235‐0442.
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: April 25, 2008
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: April 9, 2009
NAME of Project: Pipeline Security Guidelines
Name of Component: Transportation Security Administration
Name of Project Manager: James Sharp
Email for Project Manager: james.sharp@dhs.gov
Phone number for Project Manger: 571‐227‐2179
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other:
∗
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: April 25, 2008
Page 3 of 8
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: April 25, 2008
Page 4 of 8
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
As part of the Pipeline Security Guidelines, TSA recommends that each pipeline
operator establish and implement a risk‐based plan to address and document the
organization’s policies and procedures for managing security related threats,
incidents, and responses. As part of this plan, operators are recommended to provide
TSA with the 24/7 contact information of the primary and alternate security manager,
and the telephone number of the company’s security operations or control center.
TSA will use this information to contact company in the event of a change in security
threat indicators and/or incident involving the pipeline.
The information is collected on a voluntary basis from pipeline operators and not
from individuals directly.
2.
Status of Project:
This is a new development effort.
This an existing project.
Date first developed:
Date last updated:
3.
Could the project relate in any way to an individual? ∗
No.
Yes. Please provide a general description, below.
phone number
email address
4.
∗
What information about individuals could be collected, generated or retained?
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: April 25, 2008
Page 5 of 8
It is intended that individuals provide corporate issued contact information
(company issued phone/cell/email), however some organizations may provide
personal contact information (personal phone/cell/email) to provide 24/7 coverage.
5.
With whom could the information be shared?
Information will be used by TSA employees and contractors supporting Pipeline
initiatives. Information is stored in a password protected Excel spreadsheet stored on
user desktops and/or TSA network drive.
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: April 25, 2008
Page 6 of 8
6.
Is the contact information limited to non‐sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.
7.
Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
8.
No. The contact information must not be universally accessible.
Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No. Any additional sharing or use will require a separate PIA.
9.
Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?
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: April 25, 2008
Page 7 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: April 14, 2009
NAME of the DHS Privacy Office Reviewer: Nathan Coleman, Acting Director, Privacy
Compliance
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: Department of Homeland Security
General Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
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: April 25, 2008
Page 8 of 8
System covered by existing SORN: Department of Homeland Security
(DHS) Mailing and Other Lists System DHS/ALL‐002, November 25, 2008, 73 FR
71659
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
File Type | application/pdf |
File Title | DHS PRIVACY OFFICE |
Author | Claire W Barrett |
File Modified | 2009-04-14 |
File Created | 2009-04-14 |