Privacy Threshold Analysis

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 number: 01-2014
Page 1 of 8

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:
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. 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@hq.dhs.gov, phone: 202-343-1717.

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 number: 01-2014
Page 2 of 8

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

Direct Housing Program Forms (1660-NW90)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Office of Response &
Recovery (ORR) Individual Assistance
Division (IAD)

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Operational

Date first
developed:
Date of last PTA
update

August 1, 2013

Pilot launch
date:

Click here to enter a date.

NA

Pilot end date:

Click here to enter a date.

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Elizabeth McDowell

Office:

FEMA Individual Assistance

Title:

Lead Program Specialist

Phone:

540-686-3630

Email:

Elizabeth.McDowell@fema.dhs.
gov

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

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 number: 01-2014
Page 3 of 8

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: New PTA
The Federal Emergency Management Agency provides financial needs and services to individuals and
households who apply for disaster benefits in the event of a federal declared disaster, in accordance with
the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288, as amended
(the Stafford Act), collected at 42 U.S. 5121 et seq. Section 408 of the Stafford Act (42 U.S.C. § 5174)
authorizes FEMA to provide direct housing assistance, directly to individuals or households, who, as a
result of a major disaster, lack of available housing resources and would be unable to make use of
financial assistance. FEMA provides temporary housing units in the form of a manufactured home or
other readily fabricated dwellings.
FEMA is creating this new information collection request to support the direct housing operation. FEMA
will use the information collected to determine available pad sites for potential park owners/managers; to
calculate the final sales prices of manufactured housing units (MHU) when FEMA activates the Sales
Program; to act as an acknowledgement of conditions of sale, which is used to execute the sale of MHUs;
to serve as the programmatic point of transfer between the Logistics Management Directorate
Manufactured Housing Unit and Individual Assistance Direct Housing Operations Unit; to record an
occupant’s compliance with requirements for direct temporary housing assistance; and to record an
occupant’s agreement to occupy the Temporary Housing Unit (THU).
Information is collected via paper forms then uploaded into the Individual Assistance (IA) IT system,
which maintains the information on the Individual and Households Program. FEMA staff enters the
information into the Housing Operations Management Enterprise Systems (HOMES) database that is
used to coordinate the Direct Housing Assistance for disaster survivors. Under this information collection,
FEMA will collect information from members of the public, owners/managers of the properties hosting
MHUs, as well as IHP applicants in the THUs.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology please stop here and contact the DHS
Privacy Office for further guidance.

Closed Circuit Television (CCTV)
Social Media
Web portal 1 (e.g., SharePoint)
Contact Lists
None of these

3. From whom does the Project or
Program collect, maintain, use, or

1

This program does not collect any personally
identifiable information 2

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

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 number: 01-2014
Page 4 of 8

disseminate information?
Please check all that apply.

Members of the public
DHS employees/contractors (list components):
FEMA
Contractors working on behalf of DHS
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?

From FEMA employees/contractors:
Name, Signature, Phone number
From IA applicants:
Name, Signature, Registration ID #, Address, County, Phone number, Household member name,
Relationship status, Age, Sex
From other individuals:
Name, Title, Signature (as a witness, as on FF 09-0-135; or as certification on FF 009-0-137)
4(a) Does the project, program, or system
retrieve information by personal identifier?
4(b) Does the project, program, or system
use Social Security Numbers (SSN)?
4(c) If yes, please provide the specific legal
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
an information technology/system, does it
2

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used: Registration ID and Name
No.
Yes.
Click here to enter text.

Click here to enter text.

No. Please continue to next question.

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.

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 number: 01-2014
Page 5 of 8

relate solely to infrastructure?

Yes. If a log kept of communication traffic,
please answer the following question.

For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?
4(f) If header or payload data 3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?

No.
Yes. If yes, please list:
IA (formerly called NEMIS-IA)

6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?
6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?
8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have

No.
Yes. If yes, please list:
Click here to enter text.
Choose an item.
Please describe applicable information sharing
governance in place: N/A

No.
Yes. If yes, please list:

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting

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 Xacta.

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 number: 01-2014
Page 6 of 8

requested access to their PII?
9. Is there a FIPS 199 determination? 4

maintained: The FEMA Disclosure Office maintains
accounting of PII disclosures and requests.
Unknown.
No.
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 COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Lane Raffray

Date submitted to Component Privacy
Office:

January 5, 2015

Date submitted to DHS Privacy Office:

April 28, 2015

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: DHS/FEMA/PIA-027 – National Emergency Management Information System-Individual
Assistance (NEMIS-IA) Web-based and Client-based Modules
SORN: DHS/FEMA-008 - Disaster Recovery Assistance Files (April 30, 2013, 78 FR 25282)

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

4

Eric M. Leckey

FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

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 number: 01-2014
Page 7 of 8

PCTS Workflow Number:

1083217

Date approved by DHS Privacy Office:

April 30, 2015

PTA Expiration Date

April 30, 2018
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

Form/Information Collection
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.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.

System covered by existing PIA
PIA:

If covered by existing PIA, please list: DHS/FEMA/PIA-027 – National Emergency
Management Information System-Individual Assistance (NEMIS-IA) Web-based and
Client-based Modules
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/FEMA-008 - Disaster Recovery Assistance
Files (April 30, 2013, 78 FR 25282)
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
FEMA’s 1660-NW90 is a new information collection to support its direct housing operation, which is part
of its Individual Assistance program. FEMA has drafted a new e3 Privacy Act Statement to adhere to the
forms used in this ICR. The PTA notes that the information FEMA collects under this ICR is entered into
the HOMES module of the Individual Assistance (formerly NEMIS-IA) IT system.
As such, this information should be covered within the IA PIA, which is due for an update this year.

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 number: 01-2014
Page 8 of 8

FEMA should ensure that this ICR and its relevant details (e.g. individuals, data elements collected,
sharing, etc.) are represented in the new IA PIA.
Furthermore, the DHS/FEMA 008 SORN that covers IA records is due for a biennial review this year as
well. Here again, FEMA should ensure that any new categories of records created by this ICR are
included in the updated SORN. FEMA should review the routine uses of the SORN to ensure that the
sharing of information collected through this ICR is covered under the DHS/FEMA 008 SORN.