Privacy Threshold Analysis (PTA)

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 1 of 7

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
Senior Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
PIA@dhs.gov

Upon receipt from your 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: 202-343-1717.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

FEMA Individual Assistance Program Effectiveness & Recovery Survey
Collection 1660-0128

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Customer Satisfaction
Analysis Section of the
National Processing Service
Centers Division

TAFISMA Name:

Click here to enter text.

TAFISMA
Number:

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Update

PROJECT OR PROGRAM MANAGER
Name:

Kyle M. Mills, P.E., Section Manager or Maggie Billing, Program Analyst

Office:

Customer Satisfaction
Analysis Section

Title:

940 891-8500 Switchboard
Phone:

940 891-8881 Kyle Mills

Email:

940 891-8709 Maggie Billing

See Name Above
kyle.mills@fema.dhs.gov
maggie.billing@fema.dhs.gov

INFORMATION SYSTEM SECURITY OFFICER (ISSO)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

ROUTING INFORMATION
Date submitted to Component Privacy Office:

August 15, 2013

Date submitted to DHS Privacy Office:

August 20, 2013

Date approved by DHS Privacy Office:

September 23, 2013

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 3 of 7

SPECIFIC PTA QUESTIONS
1. Please describe the purpose of the project or program:
Please provide a general description of the project and its purpose in a way a non-technical person could
understand.
FEMA’s Recovery Directorate, National Processing Service Center Division administers the Individual
Assistance (IA) Program Effectiveness & Recovery Survey.

This survey is conducted approximately 60-90 days after the close of the application period to
measure overall satisfaction with FEMA information, support, with FEMA assistance and
timeliness in correlation with expectations and current level of recovery and to gather
suggestions for improvement based on the voice of the customer. Results may also be used to
report quarterly performance for the Government Performance Results Act.
Additional surveys approved under separate collections are conducted at varying times in the
disaster recovery period to measure customer service at those stages, such as, after registration or
contact with a representative, after using the internet, after visiting a Disaster Recovery Center.
Disaster survivor data is randomly imported from records stored in electronic data files and displayed on a
screen containing the survey questions. Responses to the surveys are stored in electronic data files.
Monitoring for quality assurance is recorded in an electronic file.
This purpose is consistent with FEMA’s Strategic Plan and the mandates of Exec. Order Nos. 12862,
13411, and 13571 and the Government Performance and Results Acts (GPRA).

2. Project or Program status
1995
Date first developed:
February 15, 2011
Date last updated:

Choose an item.
Pilot launch date:
Pilot end date:

N/A
N/A

DHS Employees
3. From whom does the Project or
Program collect, maintain, use or
disseminate information?
Please check all that apply.

1

Contractors working on behalf of DHS
Members of the public
This program does not collect any personally
identifiable information1

DHS defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the
identity of an individual to be directly or indirectly inferred, including any information that 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. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial
harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 4 of 7

4. What specific information about individuals could be collected, generated or retained?
Please provide a specific description of information that might be collected, generated or retained such
as names, addresses, emails, etc.
The following data is imported and retained based on the type of survey being administered:
1) Applicant name, phone number(s), mailing address, damaged address, disaster number, registration
identification number, date of registration, registrar name, date of loss, type of loss, damage to home,
damage to personal property, damage to access, emergency needs, evacuation needs, disability needs,
damage to business, current location, type of home, insurance(s), ownership, income, age, number of
dependents, self-employed, referrals to other agencies, subsequent contact date, summary line from the
comment, type of call, and representative name are imported from the IA Client application of the
NEMIS-IA system replicated to the Enterprise Data Warehouse.
The imported data is stored with the survey responses in the Customer Satisfaction Analysis System
(CSAS).
Monitoring for quality assurance is recorded through the Quality Assurance Recording System (QARS).
Does the Project or Program use Social
Security Numbers (SSNs)?
If yes, please provide the legal authority for
the collection of SSNs:
If yes, please describe the uses of the SSNs
within the Project or Program:

5. Does this system employ any of the
following technologies:

No
N/A
N/A

Closed Circuit Television (CCTV)
Sharepoint-as-a-Service

If project or program utilizes any of these
technologies, please contact Component Privacy
Officer for specialized PTA.

Social Media
Mobile Application (or GPS)
Web portal2
None of the above

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)?

2

No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

Informational and collaboration-based portals in operation at DHS and its components which collect, use,
maintain, and share limited personally identifiable information (PII) about individuals who are “members” of the
portal or who seek to gain access to the portal “potential members.”

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 5 of 7

If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.

No.
6. Does this project or program connect,
receive, or share PII with any other
DHS programs or systems4?

Yes. If yes, please list:

Data received from the Enterprise Data
Warehouse
Monitored through the Quality Assurance
Recording System (QARS)

7. Does this project or program connect,
receive, or share PII with any external
(non-DHS) partners or systems?

No.
Yes. If yes, please list:
Click here to enter text.

Is this external sharing pursuant to new
or existing information sharing access
agreement (MOU, MOA, LOI, etc.)?

Choose an item.
Please describe applicable information sharing
governance in place.
Click here to enter text.

3

When data is sent over the Internet, each unit transmitted includes both header information and the actual data
being sent. The header identifies the source and destination of the packet, while the actual data is referred to as the
payload. Because header information, or overhead data, is only used in the transmission process, it is stripped from
the packet when it reaches its destination. Therefore, the payload is the only data received by the destination system.
4 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
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 6 of 7

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Lane Raffray

Date submitted to DHS Privacy Office:

Click here to enter a date.

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: This ICR will be covered by a new PIA for the CSAS IT System that stores and maintains the
survey data.
SORN: DHS/FEMA 008 Disaster Recovery Files System of Records (April 30, 2013, 78 FR 25282) &
DHS/FEMA 002 Quality Assurance Recording System (QARS) System of Records (February 15, 2011
76 FR 8758).
The QARS SORN is being updated to include the Customer Satisfaction Analysis Section recording of its
employees administering surveys and assessments to IA applicants.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Jameson Morgan

Date approved by DHS Privacy Office:

September 23, 2013

PCTS Workflow Number:

992047
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

IT System
If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
New information sharing arrangement is required.
DHS Policy for Computer-Readable Extracts Containing Sensitive PII
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.

PIA:

New PIA is required. Covered by forthcoming PIA for the CSAS IT System.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: November 6, 2012
Page 7 of 7

If covered by existing PIA, please list: Click here to enter text.
System covered by existing SORN. A SORN Update is also required.
SORN:

If covered by existing SORN, please list: DHS/FEMA-002 – Quality Assurance Recording
System; DHS/FEMA-008 - Disaster Recovery Assistance Files
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The DHS Privacy Office agrees with FEMA Privacy Office’s Assessment. This system requires
coverage under the forthcoming PIA for the CSAS IT System, and under the DHS/FEMA 008 Disaster
Recovery Assistance Files SORN, and the DHS/FEMA 002 Quality Assurance Recording System
(QARS) SORN after being updated. Also, any forms developed through this program where a member
of the public provides information must include an approved Privacy Act Statement.
A PIA is required for this system since it is collecting and storing a wide array of PII from members of
the public, and conducting surveys using this PII for quality assurance purposes. There is currently no
PIA that covers this collection of information. The forthcoming DHS/FEMAPIA for the CSAS IT
system will cover the collection and storage of the survey data in this system. The DHS/FEMA – 008
Disaster Recovery Assistance Files SORN covers the data that is collected as a result of individuals
applying for FEMA disaster assistance. This data is used to help customer service representatives
contact members of the public and conduct surveys more accurately and efficiently. The DHS/FEMA –
002 QARS SORN will be updated to include the Customer Satisfaction Analysis Section recording of
its employees administering surveys and assessments to Individual Assistance applicants. This update
will help FEMA provide better customer service and should produce more accurate survey results. Any
forms developed through this program where a member of the public provides information must
include an approved Privacy Act Statement as required by the Privacy Act of 1974. This PTA should
be reviewed every year until the PIA is completed.