Ipa

U.S. DEPARTMENT OF

HOUSING AND URBAN DEVELOPMENT

INITIAL PRIVACY ASSESSMENT (IPA)

Pay For Success Demonstration

Office of Special Needs Assistance Programs

Instruction & Template

May 28, 2015

INTRODUCTION

What is an Initial Privacy Assessment?

An Initial Privacy Assessment (IPA) is designed to assess whether a Privacy Impact Assessment (PIA), a Privacy Act system of records notice (SORN), and/or other related privacy documents are required. The responses to the IPA will provide a foundation for determining if either a PIA or SORN or both will be required, and will also help to identify any policy concerns.

The IPA incorporates the matters previously addressed in the Department’s Personally Identifiable Information (PII) Survey, and thus replaces the survey.

When should an IPA be completed?

An IPA should be completed for all information collection activities, whether the system is electronic or contains only records in paper form, and should be completed before commencement of any testing or pilot project of an information system or prior to implementing new information collections requests. Additionally, an IPA should be completed any time there is a change to the information system or collection to determine whether there are any privacy issues as a result of such a change.

Who should complete the IPA?

The IPA should be written and reviewed by a combination of the component’s (e.g., Privacy Act Officer, System Owner, Project Leaders, Paperwork Reduction Act Compliance Officers), and the program-specific office responsible for the system, project or information collections.

How is the IPA related to the Capital Planning, Certification and Accreditation, and the Paperwork Reduction Act process?

Upon completion and approval of the IPA by the Privacy Officer the official document may be uploaded into the C&A tool, and provided as part of the IT Capital Planning, and Paperwork Reduction Act package as validation of the completed evaluation. The completed IPA demonstrates that the program components have consciously considered privacy and related requirements as part of the overall information activities. For an IT system that does not require a C&A, such as a minor application that runs on a system that does require a C&A, an IPA still should be completed to determine if other related privacy documentation are required for that system or project.

Where should the completed IPA be sent?

A copy of the completed IPA should be sent to the Office of Privacy Project Leads for review. The Privacy Officer will review the IPA and determine what additional privacy documentation is required, and then will advise the Program component accordingly.

Initial Privacy Assessment

INFORMATION ABOUT THE SYSTEM OR PROJECT

Date Submitted for Review: May 28, 2015 Project Name/Acronym: Pay For Success Demonstration (PFS Demonstration) System Owner/Contact information: Marlisa Grogan/202-402-4350/ Marlisa.M.Grogan@hud.gov Project Leader/Contact Information: Michael Roanhouse/202-402-4482/ Michael.Roanhouse@hud.gov Which of the following describes the type of records in the system:

		Paper-Only
		Combination of Paper and Electronic
		System
		Other: Please describe below the type of project or system, including paper based Privacy Act System of Records, Rules, or Technologies’. Also, indicate whether this is a revision/update for an existing system or project. Applicants will submit applications electronically via email. Applications will consist of narrative answers as well as electronic attachments. This is a new project; there are no previous submissions on file.

Note: For this form purpose, there is no distinction made between technologies/systems managed by contractors. All technologies/systems should be initially reviewed for potential privacy impact.

Section I: The Entire IPA (Sections I and II) Should be Completed for New Systems or Projects. If this is an Existing System or Project Skip to Section II. Unless requested by the Office of Privacy, this section should not be completed for an existing System or Project.

Question 1: Provide a general description of the system of

Project. The following questions are intended to define the scope of the information in the system, information collection, or project, specifically the nature of the information and the sources from which it is obtained.

1. From whom is the information collected (i.e., government employees, contractors, or consultants, state, local government entities, or general public)?

Eligible applicants include public and private nonprofit organizations. NOFA respondents applying for funding will provide information about their organization’s experience, staff’s experience, and their proposed program design.

2. What is the functionality of the system, information collection, or project and the purpose that the records and/or system serve?

Applications will be collected via email and reviewed by a panel consisting of HUD staff and other federal partners. The purpose of this information is to accurately assess the eligibility of applicants and to determine those applicants that are most qualified to carry out grant activities.

c. How is information transmitted to and from the system, information collection, or project?

Applications will be emailed from the applicant to a HUD email account.

d. What are the interconnections with other systems or projects?

Not applicable.

QUESTION 2: What is the Status of system, information collection, or project

1. If this is a new system, information collection, or project, specify the expected production date.

HUD expects to publish the NOFA by late summer. Applications will be accepted for the following 120 days. HUD may extend this deadline if necessary.

2. If an existing system, information collection, or project, specify the date of production.

Not applicable.

QUESTION 3: Does this system, information collection, or project collect personal identifiers/sensitive information

YES

NO

Does the system, information collection, or project collect personal/sensitive information? (e.g. name, address, personal email address, gender/sex, race/ethnicity, income/financial data, employment history, medical history, Social Security Number, Tax Identification Number, Employee Identification Number, FHA Case Number). Includes PII that may be part of a registration process?

If yes, specific data sets collected or provided, and the legal authorities, arrangement, and/or agreement authorize the collection of information (i.e. must include authorities that cover all information collection activities, including Social Security Numbers)?

Applicants will need to provide information contained in the SF-424, including applicant contact information, the name of the authorized representative and the Tax Identification number. The SF-424 is a required document for program NOFAs per HUD’s 2015 NOFA General Section.

QUESTION 4: Does the information about individuals identify particular individuals (i.e., is the information linked or linkable to specific individuals, often referred to as personally identifiable information?)

Yes, the applicant point of contact and authorized representative must be specific individuals for whom contact information (i.e., telephone number and email address) is provided.

QUESTION 5: What type of Notice(s) are provided to the individual on the scope of information collected, the opportunity to consent to uses of said information, the opportunity to decline to provide information. (A notice may include a posted privacy policy, a Privacy Act notice on form(s), and/or a system of records notice published in the Federal Register.)

1. Was any form of notice provided to the individual prior to collection of information? If yes, please provide a copy of the notice as an appendix. (A notice may include a posted privacy policy, a Privacy Act notice on form(s), and/or a system of records notice published in the Federal Register.) If notice was not published, why not?

All requirements related to the collection of information is included in the PFS Demonstration NOFA, which HUD expects to publish this year. The only personal information collected is on the SF-424 which is a standard government form required to receive funding.

2. Do individuals have an opportunity and/or right to decline to provide information?

Yes, although by not providing this information, the application will be incomplete and not considered for funding.

3. Do individuals have an opportunity to consent to particular uses of the information, and if so, what is the procedure by which an individual would provide such consent?

Signing the SF-424 provides consent for HUD to contact the applicant point of contact and the authorized representative regarding developments on their application.

QUESTION 6: Is there a Certification & Accreditation record for your system? (This question does not apply to Information Collection Requests)
Not applicable. Specify below the systems categorization. If not available identify the FISMA-reported system whose Certification and Accreditation covers this system. Not applicable.
Confidentiality		Low		Moderate		High		Undefined
Integrity		Low		Moderate		High		Undefined
Availability		Low		Moderate		High		Undefined

SECTION II - The Entire IPA should be completed for New Systems or Projects. If this is an Existing System or Project Complete Only Complete This Section.

QUESTION 1: When was the system, information collection, or project developed?

No changes have been made; this is a new program with no previous data collection. The program was only funded as of the FY2014 and FY2015 Federal Budgets. There is no formal electronic system for the collection of applications; applications will be collected using the HUD email system.

QUESTION 2: If an existing system, information collection, or project, has the system or project undergone any changes since April 17, 2003?

No changes have been made; this is a new program with no previous data collection.

QUESTION 3: If an existing system, information collection, or project, has the system or project, explain the changes the system or project will be undergoing as part of this renewal/update process.

No changes have been made; this is a new program with no previous data collection.

QUESTION 4: Do the changes to the system, information collection, or project involve a change in the type of records maintained, the individuals on whom records are maintained, or the use or dissemination of information from the system?

No changes have been made; this is a new program with no previous data collection.

QUESTION 5: Please indicate if any of the following changes to the system or project have occurred: (Mark all boxes that apply.)

No changes have been made; this is a new program with no previous data collection.

	A conversion from paper-based records to an electronic system.
	A change from information in a format that is anonymous or non-identifiable to a format that is identifiable to particular individuals.
	A new use of an IT system, including application of a new technology that changes how information in identifiable form is managed. (For example, a change that would create a more open environment and /or avenue for exposure of data that previously did not exist.)
	A change that results in information in identifiable form being merged, centralized, or matched with other databases.
	A new method of authenticating the use of an access to information in the identifiable form by members of the public.
	A systematic incorporation of databases of information in identifiable form purchased or obtained from commercial or public sources.
	A new interagency use of shared agency function that results in new uses or exchanges of information in identifiable form.
	A change that results in a new use of disclosure of information in identifiable form.
	A change that results in new items of information in identifiable form being added into the system.

QUESTION 6: Does a PIA for the system or project already exist? If yes, please provide a copy of the notice as an appendix.

No, the information is organization level. No personal/sensitive information is collected beyond the contact information collected for the point of contact and the authorized representative on the SF-424.

Privacy Office determination

(To be completed by the Privacy Office)

	This is NOT a privacy sensitive system, information collection or project – the system, information collection, or project contains no personal identifiers/sensitive information
	This IS a Privacy Sensitive Project
	IPA sufficient at this time
	A PIA is required
	The existing PIA requires an update/deletion
	A SORN is required
	The existing SORN requires an update or should be deleted
	Other
COMMENTS:

DOCUMENT ENDORSMENT

DATE REVIEWED:

PRIVACY REVIEWING OFFICIALS NAME:

The IPA is “not” an official document until all signatures are obtained for this page.

By signing below the Program Office or Support Office attest that the content captured in this document is accurate and complete and meet the requirements of applicable federal regulations and HUD internal policies.

SYSTEM OR PROJECT OWNER << INSERT NAME/TITLE>>		Date
<<INSERT PROGRAM OFFICE>>
PROGRAM AREA MANAGER <<INSERT NAME/TITLE>>		Date
<<INSERT PROGRAM OFFICE>>
CHIEF PRIVACY OFFICER, <<INSERT NAME>>		Date
Office of the Chief Information Officer
U. S. Department of Housing and Urban Development

11