Privacy Threshold Analysis (PTA)

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

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
PIA@hq.dhs.gov

Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.
Privacy Threshold Analysis – IC/Form

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

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:
Form Title:
Component:

064-0-9
FEMA/EMI Independent Study Course Enrollment Application
Federal Emergency
Office:
Emergency Management
Management Agency
Institute
(FEMA)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
FEMA/EMI Independent Study Course Enrollment Application
OMB Control
1660-0046
OMB Expiration
March 31, 2017
Number:
Date:
Collection status:
Extension
Date of last PTA (if
September 1, 2012
applicable):
Name:
Office:

Phone:
Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Mark Magers
Emergency Management
Title:
Instructional Designer
Institute
301-447-1038
Email:
mark.magers@fema.dhs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Sherina Green
Information Management
Management and Program
Title:
Division
Analyst
Institute
Sherina.Greene@dhs.gov
202-646-4343
Email:

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

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
The purpose of the EMI Independent Study Course Enrollment Application, FEMA Form
064-0-9, is to register individuals desiring to take an independent study course. EMI
provides training to Federal, state, local, tribal, volunteer, public and private sector
officials to strengthen emergency management core competencies. The student will
review the coursework and take a final examination to gauge the level of knowledge
achieved from the material presented. Successfully completing a course results in a
certificate being generated for the individual, this may be applied towards continuing
education credits and college credit.
FEMA reports student completion data to State Training Officers (STO) as appropriate.
STOs manage and track training requirements and completions within the State, Local,
Tribal, and Territorial (SLTT) government population associated with their respective
SLTT. STOs have approval authority for enrollment requests for EMI classroom-based
courses for students from their SLTT governments.

EMI collects this information to maintain a historical record of course completions and to
issue transcripts.
b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
The EMI Independent Study (IS) Program is part of the FEMA training program
authorized under the Robert T. Stafford Disaster Relief and Emergency Act, 42 U.S.C
5121-5207, Public Law 93-288 as amended. These courses are offered online by the
Emergency Management Institute (EMI).
2. Describe the IC/Form
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

a. Does this form
collect any
Personally
Identifiable
Information”
(PII 1)?
b. From which
type(s) of
individuals does
this form collect
information?
(Check all that
apply.)
c. Who will complete
and submit this
form? (Check all
that apply.)

d. How do
individuals
complete the
form? Check all
that apply.

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent residents
☒ Non-U.S. Persons.
☒ DHS Employees
☒ DHS Contractors
☒ Other federal employees or contractors.

☒ The record subject of the form (e.g., the individual
applicant).
☐ Legal Representative (preparer, attorney, etc.).
☐ Business entity.
If a business entity, is the only information
collected business contact information?
☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is NOT
the record subject. Please describe.
Click here to enter text.

☐ Paper.
☐ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via the
internet)
https://training.fema.gov/is/examnotice.aspx?eid=IS800b

1
Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which 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.

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

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
The EMI collects the following PII data elements on its Independent Study Course
Enrollment Application:
•
•
•
•
•
•

Name;
Mailing address;
Student ID number (SID);
Work Telephone number;
Home Telephone number; and
Email address.

f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply. Not applicable.
☐ Social Security number
☐ DHS Electronic Data Interchange Personal
Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global Entry,
☐ Passport Number
Pre-Check, etc.)
☐ Bank Account, Credit Card, or
☐ Driver’s License Number
other financial account number
☐ Biometrics
☐ Other. Please list:

g. List the specific authority to collect SSN or these other SPII elements.
Not applicable.

h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
Not Applicable.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice
A Privacy Act Statement will be provided.
at the time of
☐ No.

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

collection by
DHS (Does the
records subject
have notice of the
collection or is
form filled out by
third party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will

b. If electronic, how
does DHS input the
responses into the IT
system?

c. How would a user
search the
information
submitted on the

store the data from the form.
Applications are stored in the EMI database of the
"Training.fema.gov" system and website.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.

☐ Manually (data elements manually entered). Please
describe.
Click here to enter text.
☒ Automatically. Please describe.
After the student submits the exam using 064-0-9,
the student information and exam score is
automatically recorded in the EMI database of the
Training.fema.gov system and website.
☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.

2
Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which 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.

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

forms, i.e., how is the
information
retrieved?

Student information is retrieved using a SID. This
unique identifier is issued by the EMI for the
purpose of identifying the student.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
Records are destroyed immediately after data have
been entered or otherwise incorporated into the
master file or database and verified, but longer
retention is authorized if required for business use,
per EDP-2-2.
Periodic review of database to ensure database meets
all applicable retention policies.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
EMI shares student completion reports with STOs. The report provides
course completion data for individuals residing within the STO’s SLTT,
including course number and title, completion date, name, address, home
telephone number, SID and work email.
☐ No. Information on this form is not shared outside of the collecting office.

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

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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

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

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

Christopher Rogers
December 21, 2016
Click here to enter a date.

☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The FEMA Privacy Office recommends the following coverage:

PIA: DHS/FEMA/PIA-016 – Application and Registration Records for Training And Exercise
Programs (ARRTEP); and
SORN: DHS/FEMA - 011 Training and Exercise Programs (80 Fed. Reg. 3241 (Jan. 22,
2015)).

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

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Emily Stoner

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1140209
March 23, 2017
March 23, 2018

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

DHS PRIV has not received this ICR/Form.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☒ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
New e(3) statement is required.
Statement:
Need to include e(3) statement on form.
PTA:
No system PTA required.
Click here to enter text.
PIA:
PIA update is required.
If covered by existing PIA, please list: Click here to enter text.

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

If a PIA update is required, please list: DHS/FEMA/PIA-016 Application
and Registration Records for Training And Exercise Programs (ARRTEP)
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/FEMA - 011 Training and
Exercise Programs, 80 FR 3241 (Jan. 22, 2015)
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.

DHS Privacy finds that FEMA/EMI Independent Study Course Enrollment Application
(OMB 1660-0046, Form 064-0-9) is a privacy-sensitive collection, requiring both PIA
and SORN coverage. The form collects Personally Identifiable Information (PII) from
members of the public – including U.S. citizens or lawful permanent residents and
non-U.S. persons – DHS employees and contractors, and other federal employees and
contractors. The information collected includes name, mailing address, Student ID
number (SID), work telephone number, home telephone number, and email address.
The information collected is used to register individuals desiring to take an
independent study course.

The DHS Privacy Office concurs with the FEMA Privacy Office’s recommendation of
PIA coverage under DHS/FEMA/PIA - 016 Application and Registration Records for
Training And Exercise Programs (ARRTEP), which outlines FEMA’s collection of PII
to register individuals for the respective training and exercise programs and provide
training to FEMA employees, contractors, and members of the first responder and
emergency management communities. However, PRIV finds that a PIA update is
required in order to annotate in section 5.1 that student ID (SID) numbers (unique
ID) are being shared with STOs. Form 064-0-9 was previously covered under
DHS/FEMA/PIA - 022 Student Training/Exercise Application and Registration
Records (STARRS) due to the form’s collection of SPII (Social Security Numbers
(SSN)). Since this form no longer collects SPII, it will need to be listed under
DHS/FEMA/PIA-016 instead of DHS/FEMA/PIA-022.
The DHS Privacy Office concurs with the FEMA Privacy Office’s recommendation of
SORN coverage under DHS/FEMA - 011 Training and Exercise Programs, 80 FR 3241
(Jan. 22, 2015) which describes FEMA’s collection of PII of current and former FEMA
employees and contractors, current and former members of the first responder and
emergency management communities, and other individuals who have applied or
registered to participate in training and exercise programs.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

FEMA shares student completion reports (course number and title, completion date,
name, address, home telephone number, SID and work email) with State Training
Officers (STO) on a need to know basis. STOs manage and track training
requirements and completions within the State, Local, Tribal, and Territorial (SLTT)
government population associated with their respective SLTT. STOs have approval
authority for enrollment requests for EMI classroom-based courses for students
from their SLTT governments. Approval authority is covered under DHS/FEMA/PIA 016 in Section 5.1, and information sharing outside of DHS is permitted under
Routine Uses H, J, and O in DHS/FEMA - 011.
The Privacy Act Statement must be included on Form 064-0-9.
This PTA expires in 1 year.

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