Privacy Threshold Analysis (PTA) Form

U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)
Indian Housing Block Grant Program
PIH Office of Native American Programs
Instruction & Template
February 8,2019

PRIVACY THRESHOLD ANALYSIS (PTA)

The PTA is a compliance form developed by the Privacy Branch to identify the use of Personally
Identifiable Information (P11) across the Department. The PTA is the first step in the P11 verification
process, which focuses on these areas of inquiry:
•

Purpose for the information,
Type of information,

•

Sensitivity of the information,

•

Use of the information,

•

And the risk to the information.

Please use the attached form to determine whether a Privacy Impact Assessment (PTA) is required under
the E-Government Act of 2002 or a System of Record Notice (SORN) is required under the Privacy Act
of 1974, as amended.
Please complete this form and send it to your program Privacy Liaison Officer (PLO). If you have no
program Privacy Liaison Officer, please send the PTA to the HUD Privacy Branch:
John Bravacos, Senior Agency Official for Privacy
Privacy Branch
U.S. Department of Housing and Urban Development

privacy@hud.gov

Upon receipt from your program PLO, the HUD Privacy Branch will review this form. If a PTA or SORN
is required, the HUD Privacy Branch will send you a copy of the PTA and SORN templates to complete
and return.

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

Indian Housing Block Grant Program

Program:

Public and Indian Housing (PIll)

CSAM Name (if
applicable):

Click here to enter text.

.

.

Type of Project or
Program:
Date first
developed:
Date of last PTA
update:

CSAM Number
(if applicable):

Click here to enter text.

Form or other Information
Collection

Project or
program
status:

Operational

June 1, 199$

Pilot launch
date:

July 1, 1999

February 1, 2015

Pilot end date:

August 1, 1999

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

.

.

.

.

.

ATO Status (if
applicable)

.

PROJECT OR PROGRAM MANAGER
Name:
Office:
Phone:

Office of Native American
Programs
202-402-29$8

.

Title:
Email:

Director, Office of Grants
Evaluation

Gary.A.Nernec @ hud.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.

SPECIFIC PTA QUESTIONS

1.

Reason for submitting the PTA:

New PTA

Please provide a general description of the project and its pit rpose so a non-technical person could
understand. If this is an upda ted PTA, please describe what changes and/or icpgrades triggering the
itpdate to this PTA. If this is a renewal please state whether there were any changes to the project,
program, or system since the last version.

The forms included in this collection are associated with the thdian Housing Block Grant
(IHBG) program, as authorized under Title I of the Native American Housing Assistance and
Self-Determination Reauthorization Act (25 U.S.C. 4101). The IHBG program provides funding
to eligible Native American tribes and tribally designated housing entities in the form of
formula-based allocations and competitive awards. Recipients may use their IHBG funds to carry
out a range of affordable housing activities that benefit low-income Indian families living on
Indian reservations or in other Indian areas.

2. Does

this system employ the following

Social Media

technologies?

If yot, are using these technologies and want
coverage under the respective PIA for that
technology, please stop here and contact the HUD
Privacy Branch forfurther guidance.

Web portal1 (e.g., SharePoint)

El

Contact Lists

website (e.g. A website operated by
HUD, contractor, or other organization on behalf of
the HUD
Public

None of these

This program collects no personally identifiable
information2
3.

From whom does the Project or

Members of the public

Program collect, maintain, use, or
disseminate information?

Please check all that apply.

HUD employees/contractors (list programs):
Indian Housing Block Grant program

Contractors working on behalf of HUD
Employees of other federal agencies

Informational and collaboration-based portals in operation at HUD and its programs that collect, use, maintain, and share limited
personally identifiable information (P11) about individuals who are “members” of the portal or “potential members” who seek to
gain access to the portal.
2
HUD defines personal information as “Personally Identifiable Information” or P11, 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 P11” is P11, 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 P11 are treated the
same.

Other (e.g. business entity)

4. What specific information about individuals is collected, generated or retained?
Please provide a specific description of information collected, generated, or retained (such as
maiden

name,

mother’s maiden name, alias, social securIty number, passport

number,

full names,

driver’s license

number, taxpayer identtfi cation numbe,; patient identfi cation numbem; financial accottnt, credit card
number, street Internet protocol, media access control, telephone number, mobile number, business
number, photograph image, x-rays, fingerprints, biometric image, template date(e.g. retain scan, welldefined group of peopte),vehicle registration numbe,; title itumber and information about an indttviat that
is linked or linkable to one of the above (e.g. date of date, place of birth, race, religion, weight, activities,
geographical indicto rs, employment information, medial iiforination, education information, financial
information) and etc.
,

The IHBG program collects oniy the name and contact information of the IHBG recipient’s authorized
representative.
As part of the IHBG Competitive application package, applicants submit an Applicant/Recipient
Disclosure/Update Report (HUD-28$O) that collects the full name and Social Security Number or
Employee ID Number of the person authorized to execute grant applications, grant agreements, and other
documents required by the IHBG Competitive program.
4(a) Does the project, program, or system
retrieve information from the system about
a U.S. Citizen or lawfully admitted
permanent resident aliens by a personal
identifier?

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used:

4(b) Does the project, program, or system
have an existing System of Records Notice
(SORN) that has already been published in
the Federal Register that covers the
information collected?

No. Please continue to next question.
D Yes. If yes, provide the system name and
number, and the Federal Register
citation(s) for the most recent complete notice and
any subsequent notices
reflecting amendment to the system

4(c)Has the project, program, or system
undergone any significant changes since the
SORN?
4(d) Does the project, program, or system
use Social Security Numbers (SSN)?
4(e) If yes, please provide the specific legal
authority and purpose for the collection of
SSNs:

No. Please continue to next question.
Yes. If yes, please describe.
No.
Yes.
Applicants for Federal assistance are required to
submit form HUD-2880 that collects the name and
Social Security Number or Employer 10 Number of
the person authorized to submit the application on
behalf of the tribe. HUD uses this information to
identify apparent or potential conflicts of interest.

If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(g) If this project, program, or system is
an information technology/system, does it
relate solely to infrastructure?
4(f)

HUD uses $SNs to identify real, apparent, or
potential conflicts of interest.
No. Please continue to next question.

L Yes. If a log kept of communication traffic,
please answer this question.

For example, is the system a Local Area Network
(MN) or Wide Area Network (WAN)?
4(h) If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

ENo.

5.

6.

Yes. If yes, please list:

.

Does this project, program, or system
connect, receive, or share P11 with any
other HUD programs or systems?

Does this project, program, or system
connect, receive, or share P11 with any
external (non-HUD) partners or
systems?

•

Grants.gov

•

LOCCS

.

HUD’s Energy and Performance Information
Center
N 0.
Yes. If yes,

please

list:

Click here to enter text.
.

.

6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, 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_HUD_personnel?
Header:

Choose an item.
Please describe applicable information sharing
governance in place:

No.
Yes. If yes, please list:

that is placed before the actual data. The header normally contains a small number of bytes of
which is used to communicate important facts about the data that the message contains and how
to be interpreted and used. It serves as the communication and control link between protocol elements on different
Information

control information,

it

is

devices.

Payload data: The actual data to be transmitted, often called the payload of the message (metaphorically borrowing a
term from the space industry!) Most messages contain some data of one form or another, but some actually contain
none: they are used only for control and communication purposes. for example, these may be used to set up or
terminate a logical connection before data is sent.

8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of P11 to individuals/agencies who have
requested access to their P11?
9.

Is there a FIPS 199 determination?4

No. What steps will be taken to develop and
maintain the accounting: No P11 is collected or
disclosed.

LI

Yes. In what format is the accounting
maintained:
Unknown.
LINo.

LI Yes. Please indicate the determinations for each
of the following:
Confidentiality:
[1 Low LI Moderate

LI High

Integrity:
LI Low LI Moderate

LI High

Availability:
LI Low LI Moderate

LI High

PRIVACY THRESHOLD ANALYSIS REVIEW
(TO BE COMPLETED BY PROGRAM PLO)
Program Privacy Liaison Reviewer:

Arlette Mussington

Date submitted to Program Privacy
Office:

N/A

Date submitted to HUD Privacy Branch:

Click here to enter a date.

Program Privacy Liaison Officer Recommendation:
Please inclttde recommendation below, including what new privacy compliance documentation is needed.
This PTA will suffice, however; if there are any changes, an updates will be provided.

(TO BE COMPLETED BY THE HUD PRIVACY BRANCH)
HUD Privacy Branch Reviewer:

Click here to enter text.

fIPS 199 is the Edra tnloriuation Procin Sandaid Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Date approved by HUD Privacy Branch:

Click here to enter a date.

PTA Expiration Date:

Click here to enter a date.
DESIGNATION

Privacy Sensitive System:

If “no” PTA adjudication is complete.

Choose an item.

Category of System:
Determination:

Choose an item.

If “other” is selected, please describe: Click here to enter text.

LI PTA sufficient at this time.
LI Privacy compliance documentation determination in progress.
LI New information sharing arrangement is required.
LI HUD Policy for Computer-Readable Extracts Containing Sensitive P11
applies.

LI Privacy Act Statement required.
LI Privacy Impact Assessment (PTA) required.
LI System of Records Notice (SORN) required.
LI Paperwork Reduction Act (PRA) Clearance may be required. Contact
your program PRA Officer.

LI A Records Schedule may be required. Contact your program Records
Officer.
PIA
SORN

Choose an item.
If covered by existing PTA, please list: Click here to enter text.
Choose an item.

If covered by existing SORN, please list: Click here to enter text.
HUD Privacy Branch Comments:
Please describe rationale for privacy compliance determination above.
Click here to enter text.

DOCUMENT ENDORSMENT

DATE REVIEWED:
PRIVACY REVIEWING OFFICIALS NAME:

By signing below, you attest that the content captured in this document is accurate and complete
and meet the reoiirements of applicable federal regulations and HUD internal policies.

SYSTEM OWNER
Gary Nernec, Director
Office of Grants Evaluation
Office of Native American Programs

Date
CHIEF PRIVACY OFFICER
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OFFICE OF ADMINISTRATION