Privacy Threshold Analysis (PTA)

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 10, 2010
Page 1 of 6
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 from the component Privacy Office, 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 DHSConnect 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 10, 2010
Page 2 of 6
PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review: January 27, 2012
Name of Project: Update of FEMA’s Mitigation Planning Regulations
System Name in TAFISMA: None
Name of Component: Federal Emergency Management Agency
Name of Project Manager: Kathleen Smith
Email for Project Manager: Kathleen.w.smith@dhs.gov
Phone Number for Project Manager: 202 646 4372
Type of Project:
Information Technology and/or System. ∗
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
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: June 10, 2010
Page 3 of 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Under Title 44 Code of Federal Regulations (CFR) Part 201, the Federal Emergency Management
Agency (FEMA) requires State, Tribal and local governments to submit to FEMA for approval
hazard mitigation plans. Under the said CFR provision, FEMA requires a mitigation plan to be
submitted to FEMA for review and approval in order for the State/local/Tribal entity to be eligible
for certain types of FEMA mitigation grants in the future. Mitigation plans are not retrieved by
Personally Identifiable Information (PII).
On September 1, 2011, the Office of Management and Budget (OMB) approved an extension
without change of the currently approved collection of State/Local/and Tribal Hazard Mitigation
Plans and set an expiration date of September 30, 2014 under OMB Control Number 1660-0062.
FEMA is preparing a notice of proposed rulemaking to consider possible revisions to the
mitigation planning regulations under 44 CFR Part 201 to change the current State Mitigation
Plan (Standard and Enhanced) update requirements from 3 to 5 years. This proposed reduction
in the frequency of the State and Enhanced Mitigation Plan updates should result in a reduction
to the burden hours.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: February 26, 2002
Date last updated: On September 1, 2011, FEMA received approval from OMB for the
continued collection of information under OMB Control Number 1660-0062.

3.

From whom 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.

4.

Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.

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 10, 2010
Page 4 of 6
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:

5.

What information about individuals could be collected, generated or retained?
The information collection includes business points of contact to allow for correspondence
between FEMA and the States, local, and Tribal Governments submitting the Mitigation Plan.

6.

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.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 1?
No.
Yes.
Please list:

8.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.

1

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.

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 10, 2010
Page 5 of 6
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: January 27, 2012
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.
PIA is required.
System covered by existing PIA: FEMA NEMIS Mitigation eGrants
Management System

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 10, 2010
Page 6 of 6
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/FEMA-2006-0002
New SORN is required.
DHS PRIVACY OFFICE COMMENTS