PTA - BLM Paleo Resources System

DI-4012 (9/2018)
U.S. Department of the Interior

U.S. Department of the Interior
PRIVACY THRESHOLD ANALYSIS

The DI-4012 Privacy Threshold Analysis (PTA) form helps Department of the Interior (DOI) Privacy
Officials determine whether a new or revised Privacy Impact Assessment (PIA) is required in
accordance with the E-Government Act, OMB policy, and the DOI PIA Guide, and identify other related
compliance requirements for the collection, maintenance, storage, use, processing, sharing or disposal of
personally identifiable information (PII) and any activities that may have privacy implications or
otherwise impact individual privacy. See the DOI PTA Guide for guidance on completing the PTA.
PTAs must be completed and submitted to the appropriate Bureau/Office Associate Privacy Officer for
review and compliance determination. Bureau/Office Associate Privacy Officers are responsible for
overseeing and managing PTAs for their organizations.

Section 1. General Information
Question

Response

A. Project, Program or System Name:

Paleontological Resources Protection – an inter-bureau
project between BLM, BOR, FWS, and NPS.

B. Bureau or Office:

BLM HQ400 - Directorate of National Conservation
Lands and Community Partnerships

C. Program or Office:

BLM HQ420 - Division of Education, Cultural and
Paleontological Resources

D. Project/Program Manager or System
Owner:

Name: Scott Foss
Title: Division Chief HQ420
Phone: (505) 954-2147
E-mail: sfoss@blm.gov
__X_ New PTA

Provide the name for the project, program, or system
for the PTA, which may be an IT system, a project title,
program area, information collection, or other
technology.
Enter the bureau or office for the project, program, or
system.
Provide the name of the program or office within the
bureau/office.

Enter the name, title, phone number, and email address
of the Program Manager or System Owner.

E. Routing Information:

Indicate whether this is a new or updated PTA and enter
the date the PTA was completed and submitted to the
APO for privacy determination.

___ Updated PTA
Date of Submission:3-3-22

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Section 2. Project, Program or System Summary
Question

Response

A. General description of the project, program, This program will protect and preserve paleontological
or system. Please provide the utility of the
resources as required in the Paleontological Resources
Preservation Act of 2009 (and its implementing
program; how
Please provide a description of the project or program, regulations). The program will consist of general policy
including any background information to help
and guidance for preserving these resources on BLM
understand the project, program, or system. If this is
lands and a permitting system for collection of the
an updated PTA, please describe the changes that
materials by qualified researchers for reviewed research
triggered the update to this PTA. Please also indicate
projects. Additionally, this system of records will
if the PTA is being updated as part of its annual
facilitate management, tracking, and reporting activities
review.
under permits, thus allowing bureau and office staff to
ensure that permitted activities do not interfere with
management objectives for the land or with other
authorized public uses, thereby protecting Federal land
and the natural and cultural resources on that land.
B. What is the technology or format used for
the Project, Program or System?

_X_ IT System.
___ New Project or Program
___ Website
___ Web Form, Survey, or Information Collection
___ Third-Party Website
___ Social Media Application
___ SharePoint
___ Mobile Application
___ Closed Circuit Television (CCTV)
_X_ Paper-based Collection
___ Other: Describe.

C. Does this project, program or system
involve a form, survey, or information
collection?

_x__ Yes: Please describe.

Select all types of technology or sources that apply for
the PII that will be collected from or maintained on
individuals, including methods such as a paper or
electronic form or survey, website collection, social
media, or interviews over the phone or in person.

If this project, program, or system uses a form, survey,
or other information collection, select “Yes”, and
describe the specific method or format used. Include
titles and numbers or other identifying information.

This information will be collected through paper or IT
system, specifically BLM's Recreation and Permit
Tracking and Online Reporting (RAPTOR) IT system.
DI Form 9002, Paleontology Permit Application
DI Form 9003, Paleontology Permit
DI Form 9004, Paleontology Locality Record
DI Form 9005, Notice to Proceed (Paleontology)
DI Form 9006, Paleontology Permit Report
DI Form 9007, Repository Receipt of Collections
(Paleontology)
___ No
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D. Is Office of Management and Budget
(OMB) approval required for the collection?

OMB approval is required for certain collections of
information from ten or more members of the public
under the Paperwork Reduction Act.

_x_ Yes: Please provide the status of any information

collection clearance request related to this project, program,
or system, and include all OMB Control Numbers and
Expiration Dates that are applicable.

OMB Control No. 1093-0008; pending final approval
upon publication of final rule.
___ No

Section 3. Personally Identifiable Information
Question

Response

A. What categories of individuals does the
Project, Program or System collect, maintain,
store, use, process, disseminate or dispose of
PII? Please select all that apply.

_X__ Federal employees

Indicate whether the project, program or system
collects, contains, uses, or disseminates PII
information about members of the general public,
Federal employees, contractors, or volunteers; or if
the system does not contain any information that is
identifiable to individuals (e.g., statistical,
geographic, financial).

B. What specific information about
individuals will be created, collected, used,
processed, maintained, or
disseminated? Describe all the types of

information about individuals that will be created,
collected, used, processed, maintained, or
disseminated. Include any new information that may
be created, such as an analysis or report. Describe
the purpose of that collection or use of information.

_X__ Contractors
_X__ Members of the public
___ Other: Describe.
___ This project, program or system does not collect,
maintain or process PII

Names of applicants and support personnel such
as other persons who conduct or oversee work under the
permit; researchers; applicant institutional affiliation;
applicant contact information including work mailing
address, work telephone number(s), work fax number,
and/or professional email address; field contact
information; applicant and support personnel resumes,
educational institutions attended and dates of attendance
or graduation, applicant institutional affiliation,
employment information, machinery, or vehicle
identifying information as appropriate; proof of
insurance as appropriate, and other information necessary
to ensure that the applicant can perform the work
proposed under the permit. The system may also contain
records related to the assessment of civil penalties
including written notices of objection to a proposed
assessment of civil penalty, written requests for a hearing
on a final assessment of civil penalty, final
determinations, and any correspondence or record
related to the implementation of provisions related to
civil penalties under the PRPA; DOI employees,
contractors, or partners who perform paleontological
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Question

C. Is information retrieved by a unique
identifier assigned to the individual?
Describe how information is retrieved for the
project, program, or system.

Response
investigations for scientific research; employees located
at a facility that curate Federal collections; and DOI
employees who serve as contacts for processing
applications and managing permits.
_x__ Yes: Please describe.
Name, permit number
___ No

D. Is the information covered by a System of
Records Notice (SORN)? The Privacy Act

requires that agencies publish a SORN in the
Federal Register upon the establishment of a new, or
modification of an existing, system of records. For
new SORNS being developed, select “Yes”, and
provide a detailed explanation. For existing systems
of records, identify the applicable government wide,
DOI, or bureau SORN(s) that covers the system of
records with the SORN identifier and Federal
Register citation.

E. Does the Project, Program or System
collect or use Social Security Numbers
(SSNs)? List the statutory and regulatory authority
and Executive Orders that authorizes the collection
or use of SSNs to meet an official program mission
or goal.

F. Does this Project, Program or System
receive or share PII with any other internal
DOI programs or systems? Indicate whether PII
will be shared with or from internal organizations
within DOI.

_x__ Yes: Please provide the title, date, and Federal
Register citation.
INTERIOR/DOI-20, Paleontological Resources
Preservation System - 84 FR 52530 (October 2, 2019)
___ No

___ Yes: Please provide the legal authority for the
collection of SSNs and describe the uses of the SSNs
within the Project, Program or System.
_x__ No
_x__ Yes: Please describe the PII shared and purpose
of the sharing.
May be shared with other Bureaus as part of joint
research
___ No

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Question

Response

G. Does this Project, Program or System
receive or share PII with any external (nonDOI) partners or systems? i.e., Tribal, state,
or local gov, public or private partners,
NGOs, grantees, other Federal agencies, etc.
and if so, who, how and what for?

_x__ Yes: Please describe the PII shared and purpose
of the sharing.

Indicate whether PII will be shared with agencies or
organizations external to DOI. This could be other
federal, state, and local government agencies,
private sector entities, contractors or other external
third parties. For Privacy Act systems, identify the
applicable SORN and describe how an accounting of
the disclosure is maintained.

H. Is this external sharing pursuant to new
or existing information sharing agreement
(Memorandum of Understanding,
Memorandum of Agreement, Letters of
Intent, etc.)?

Information sharing agreements are generally
documented in Memorandums of Understanding,
Memorandums of Agreement, Letters of Intent, or
other documents, and outline the purpose, roles of
the parties, data ownership, authorized uses, policy,
scope, standards, procedures, practices, limitations
on re-dissemination, and safeguard requirements for
the transfer, maintenance, and disposal of PII to
ensure all parties understand and adhere to the
mutually established terms of the agreement.

May be shared with other Federal Agencies as part of
joint research; Information may be shared during tribal
consultations concerning potential impact on tribally
associated resources.
___ No

___ Yes: Please describe applicable information
sharing agreement(s) in place.
_x__ No

Section 4. PTA Review and Recommendation
Question

Response

Privacy Compliance Determination:

_x_
___
___
___
___
___
___
___
___
___
___
___

This determination is to be completed by the
Associate Privacy Officer (APO). See DOI PTA
Guide, DOI PIA Guide, related Federal laws and
policies, and Departmental guidance on privacy
requirements.

PTA is sufficient at this time
Privacy Impact Assessment (PIA) required
Adapted PIA required
System of Records Notice (SORN) required
Notice of Proposed Rulemaking/Final Rule required
Computer Matching Notice required
Computer Matching Agreement required
Privacy Act Statement required
Privacy Notice required
Specialized role-based training required
Information sharing agreement required
Further privacy compliance review is required
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U.S. Department of the Interior

___
___
___
___
Bureau Associate Privacy Officer Comments:

Provide comments or additional guidance on privacy
compliance requirements.

Refer for Security Compliance Assessment
Refer for Information Collection Clearance Review
Refer for Records Review
Other: Describe.

1018-0008 is a paper-based and electronic collection
and the BLM RAPTOR PIA is currently in final draft
awaiting DOI Privacy review.
Records are retrieved by a personal identifier, so SORN
coverage is required and provided by DOI-20.
Bureau of Land Management records for this program
are maintained under BLM 4/14 Grazing and other LandUse Lease and Permit Files--Temporary, 30 years.

Associate Privacy Officer Name:

Catherine Brean

Bureau/Office:

CATHERINE
BREAN
BLM/Associate Privacy Officer

Date:

03/03/2022

Digitally signed by
CATHERINE BREAN
Date: 2022.03.03
11:17:00 -06'00'

DOI Privacy Office Comments

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