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:

FEMA Form 070-0-0-1
National Fire Department Census

Component:

Federal Emergency
Management Agency
(FEMA)

U.S. Fire
Administration

Office:

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
National Fire Department Census
OMB Control
Number:
Collection status:
Name:
Office:
Phone:
Name:
Office:

OMB Expiration
Date:
Date of last PTA (if
applicable):

1660-0070
Extension

Click here to enter a
date.

PROJECT OR PROGRAM MANAGER
Gayle Kelch
National Fire Data Center
Title:
Statistician
301-447-1154
Email:
gayle.kelch@fema.dhs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Millicent Brown
Information Collection/Forms
Forms
Title:
Management/Information
Collections

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Manager

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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

Mission Support

Phone:

Millicent.Brown@fema.dhs.gov
Email:
SPECIFIC IC/Forms PTA QUESTIONS

202-646-2814

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 USFA is working to identify all fire departments in the United States to develop a database
that includes information related to their demographics, capabilities, and activities. The database
is used by the USFA to guide programmatic decisions and to provide the Fire Service and the
public with information about fire departments. Additionally, USFA maintains the census
database for disseminating critical fire safety and prevention information to departments. The
FEMA Critical Infrastructure Protection (CIP) program uses the census for the purpose of
distributing sensitive information to senior fire and EMS personnel. FEMA collects limited
PII (basic contact information) of fire department personnel submitting the form; however the
majority of the information maintained in the database is aggregate data, related to the fire
department and not the individual.
Public Law 93-498 provides for the gathering and analyzing of data as deemed useful and
applicable for fire departments. The National Fire Department Census evolved from
recommendations of the Blue Ribbon Panel. In the spring of 1998, the Director of the Federal
Emergency Management Agency (FEMA) convened a Blue Ribbon Panel of prominent
members of the U.S. fire service to review the structure, mission, and purpose of the U.S. Fire
Administration (USFA) and to make recommendations for the future of the Federal fire focus.
The Blue Ribbon Panel noted the lack of a comprehensive list of fire departments and baseline
data for the definition of the composition, capabilities, and activities of the nation's fire
service. Their recommendation was for the USFA to develop a fire department census.
The purpose of this collection is to assist in the development of a fire service census that
captures demographic information that will help clarify the perception issue and establish
baselines and benchmarks for USFA activities, and identify and maintain the demographics of
fire departments in the United States by conducting a fire services census.
USFA receives many requests from fire service organizations and the public for information
related to fire departments, including total number of departments, number of stations per
department, population protected, and number of firefighters. Additionally, USFA maintains
the census for the purpose of disseminating fire safety and prevention information to fire
departments across the country.
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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

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.
U.S. Fire Administration
Public Law 93-498 provides for the gathering and analyzing of data as deemed useful and
applicable for fire departments.

2. Describe the IC/Form
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.)

☒ 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.

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

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

☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
Fire department personnel representing the fire
department (e.g., Fire Chief).

☒ Paper.
☐ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via
the internet)
Provide link:

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 USFA collects the following PII data elements from fire department points of contact:
• Name;
• Telephone number;
• Fax 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. No.
☐ 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
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:

g. List the specific authority to collect SSN or these other SPII elements.
Sensitive Personally Identifiable Information (SPII) is not collected on this 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

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.
Sensitive Personally Identifiable Information (SPII) is not collected on this form.
i.

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

☒ Yes. Please describe how notice is provided.
A privacy notice will be provided.
☐ No.

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?

Privacy Threshold Analysis – IC/Form

store the data from the form.
USFA Web Farm
☐ 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.
Fire department respondents enter the data
manually. Once the data is in the system, then they
can retrieve the submitted information at a later
date and provide updates/changes to only specific
data elements (i.e., there is no need to resubmit all
of the information if there are no changes).
☐ Automatically. Please describe.
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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

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

Click here to enter text.

☐ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
The forms are retrieved by using the Fire
Department Identification Number (FDID) and
state location.
Fire department records are maintained until the fire
department notifies USFA that the department no
longer exists or has merged with another fire
department, per FEMA Records Schedule EDP-2-4.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
The US Fire Administration adheres to the FEMA
that records are
Disposition schedule, which provides the timeframes
disposed of or deleted
for records destruction, and or disposal of relevant
in accordance with
documents associated with each Preparedness Grant
the retention
Program.
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.

☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
The census data are available publicly on USFA’s website with the exception of the
contact person’s information (i.e., name, telephone number, fax number, and email
address fields) and the specialized services provided data.
☐ No. Information on this form is not shared outside of the collecting office.

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

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
November 18, 2016
Click here to enter a date.

☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
The information collected will be not be
stored in a system of record. Therefore, no
Privacy Act Statement is needed. However,
a Privacy Notice will be provided.

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

PIA: DHS/ALL/PIA – 006 Department of Homeland Security General Contact List.
SORN: Not applicable; the application does not collect or retrieve information using
personal identifiers.

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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:

Kevin Mullinix

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

1137543
February 14, 2017
February 14, 2020

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

Choose an item.

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
e(3) statement not required.
Statement:
Privacy Notice is required.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
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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 covered by existing PIA, please list: DHS/ALL/PIA – 006 Department
of Homeland Security General Contact List
If a PIA update is required, please list: Click here to enter text.
SORN:
Choose an item.
If covered by existing SORN, please list: Click here to enter text.
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.

The DHS Privacy Office finds that the National Fire Department Census FORM 070-00-1 is a privacy sensitive collection, requiring PIA coverage. FEMA U.S. Fire
Administration (USFA) collects contact information that is used to guide
programmatic decisions and to provide USFA and the public with information about
fire departments. Though the form requires the submission of contact information
from the individual submitting the form on behalf of an organization, that
information is not used to retrieve information, and does not meet the requirements
to be considered part of a system of records. Therefore, SORN coverage is not
necessary.
PRIV finds that a Privacy Act e(3) Statement is not required in this instance because,
as PRIV understands it, no information is being collected that will be stored in a
system of records. PRIV requires a privacy notice, which serves a similar purpose to
the Privacy Act Statement, and allows individuals to be informed about the collection
and use of their information before providing it to DHS.
PRIV agrees with FEMA’s assertion that PIA coverage is provided by DHS/ALL/PIA –
006 Department of Homeland Security General Contact List, which assess the risks
associated with the collection of contact lists that are used to facilitate the
dissemination of information regarding the Department’s operations and to
facilitate the collaboration of partners who are working with the Department on
various projects.

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