Initial Privacy Assessment

IPA Form 02-17-16.docx

Public Housing Agency (PHA), Lease Requirements, Recordkeeping Requirements

Initial Privacy Assessment

OMB: 2577-0006

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U.S. DEPARTMENT OF

HOUSING AND URBAN DEVELOPMENT



Initial Privacy Assessment


Public Housing Authority (PHA), Lease Requirements, Recordkeeping Requirements

Office of Public and Indian Housing



February 11, 2016


INITIAL PRIVACY ASSESSMENT (IPA)

The Initial Privacy Assessment (IPA) is use to determine whether a Privacy Impact Assessment (PIA) is required under the E-Government Act of 2002. The IPA is also used to determine if a System of Records Notice (SORN) is required under the Privacy Act of 1974.


The IPA is an administrative form created by the Privacy Branch to efficiently and effectively identify the use of Personally Identifiable Information (PII) across the Department. The IPA focuses on three areas of inquiry:

  • Business data and business processes within each HUD program.

  • Potential connections with individuals including the use of PII – any use of social security numbers must be specifically identified.

HUD’s program and support offices should ensure that its respective IPA is completed and sent to the Privacy Branch for approval. If SSNs are to be used, the IPA specifically identifies the justification and authority for using SSNs. Upon receipt of the IPA, the Privacy Branch determines the applicability of other privacy compliance requirements including the PIA and SORN. The IPA is complete when the Privacy Branch signs it and sends the final copy back to the identified point of contact.

Please complete this form and send it to the HUD Privacy Branch staff.

Janice Noble

Acting, Branch Chief

Privacy Branch

U.S. Department of Housing and Urban Development

Privacy@hud.gov

If a PIA or SORN is required, a copy of the Privacy Impact Assessment and System of Records Notice form is available on the HUD Privacy Branch website, http://hudatwork.hud.gov/HUD/cio/po/i/privacy, on HUD@Work or directly from the HUD Privacy Branch via email: privacy@hud.gov to complete and return.

INITIAL PRIVACY ASSESSMENT (IPA) SUMMARY INFORMATION

Date Submitted for Review: 02/11/2016

Name of System or Project: Public Housing Agency (PHA) Lease and Grievance Requirements

System Name in CSAM: n/a

Name of Program Office: Office of Public and Indian Housing

Name of Project Manager or System Owner: Sheba Cousins

Email for Project Manager or System Owner: Sheba.cousins@hud.gov

Phone Number for Project Manager or System Owner: 202-402-2986

Type of Project:


Information Technology and/or System

A Notice of Proposed Rule Making or a Final Rule:

Form or other Information Collection:

Other:


SPECIFIC QUESTIONS

  1. Describe the project and its purpose:

Public Housing Agencies (PHAs) are required by the Housing Act of 1937 to collect leases and acknowledgement of the local grievance procedures both signed at the time residents begin renting. PHAs are also required to retain these documents as a part of their record keeping and update them if there are changes to family structure or grievance claims.

2. Status of Project:

This is a new development effort.

This is an existing project.

Date first developed:

Date last updated: June 7, 2012

This is a revision of a currently approved collection.

  1. From whom do you collect, process, or retain information on: (Please check all that apply)

HUD Employees

Contractors working on behalf of HUD

The Public

The System does not contain any such information.

  1. Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)

No.

Yes. Why does the program collect SSNs? Provide the function of the SSN and the legal authority to do so:

<Please explain the purpose of the collection, the function and the legal authority to collect, maintain or transmit the SSN.>

  1. What information about individuals could be collected, generated or retained?

This collection does not collect information about individuals; it informs PHAs of their recordkeeping and lease requirements.

  1. If this project is a technology/system, does it relate solely to infrastructure? [For example, is the system a Local Area Network (LAN) or Wide Area Network (WAN)]?

No. Please continue to the next question.

Yes. Is there a log kept of communication traffic?

No. Please continue to the next question.

Yes. What type of data is recorded in the log? (Please choose all that apply.)

Header

Payload Please describe the data that is logged.

<Please list the data elements in the log.>

  1. Does the system connect, receive, or share Personally Identifiable Information with any other HUD systems?

No.

Yes. Please list the systems:

Is this external sharing pursuant to new or existing information sharing access agreement (MOU, MOA, LOI, etc.)?


  1. Does the system meet all of the following requirements? n/a

There will be a group of records under the control of an agency that contains a personal identifier (such as a name, date of birth, SSN, Employee Number, fingerprint, etc.) of U.S. citizens and lawful permanent residents;

Contains at least one other item of personal data (such as home address, performance rating, blood type, etc.); and

The data about the subject individual IS retrieved by the name or unique identifier assigned to the individual.

No.

Yes.

If yes is there an existing System of Record Notice?

No.

Yes.


  1. Is there an Authorization to Operate record within OCIO’s FISMA tracking system CSAM?

Unknown

No

Yes. Please indicate the determinations for each of the following:

Confidentiality: Low Moderate High

Integrity: Low Moderate High

Availability: Low Moderate High

PRIVACY DETERMINATION

(TO BE COMPLETED BY THE HUD PRIVACY BRANCH)


Date reviewed by the HUD Privacy Branch: <Insert Date.>

Name of the HUD Privacy Branch Reviewer: <Please enter name of reviewer.>

DESIGNATION

This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable Information.


This IS a Privacy Sensitive System

Category of System

IT System

Legacy System

HR System

Rule

Other: ____________________________

Determination

IPA sufficient at this time

Privacy compliance documentation determination in progress

PIA is not required at this time

PIA is required

System covered by existing PIA:

New PIA is required

PIA update is required

SORN not required at this time

SORN is required

System covered by existing SORN:

New SORN is required

HUD PRIVACY BRANCH COMMENTS:


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 requirements of applicable federal regulations and HUD internal policies.








SYSTEM OWNER

Sheba Cousins,Housing Program Specialist


Date

Public and Indian Housing















PROGRAM AREA MANAGER

Milan M. Ozdinec, Deputy Assistant Secretary


Date

OFFICE OF PUBLIC HOUSING & VOUCHER PROGRAMS














CHIEF PRIVACY OFFICER

<<INSERT NAME/TITLE>>


Date

OFFICE OF THE EXECUTIVE SECRETARIAT







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