PTA - NPS 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 FWS, BOR, BLM, and NPS.

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.

B. Bureau or Office:

National Park Service

Enter the bureau or office for the project, program or
system.

C. Program or Office:
Provide the name of the program or office within the
bureau/office.

D. Project/Program Manager or System
Owner:

Natural Resource Stewardship and Science Directorate
(NRSS)

E. Routing Information:

Name: Vincent L. Santucci
Title: Senior Paleontologist / Paleontology Program
Coordinator
Phone: 202-513-7186
E-mail: Vincent_Stantucci@nps.gov
X_ New PTA

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

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

Date of Submission: 3/3/2022

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U.S. Department of the Interior

Section 2. Project, Program or System Summary
Question

Response

A. General description of the project, program
or system. Please provide the utility of the
program; how

This program will protect and preserve paleontological
resources as required in the Paleontological Resources
Preservation Act of 2009 (and its implementing
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 NPS
understand the project, program or system. If this is an lands and a permitting system for collection of the
updated PTA, please describe the changes that
materials by qualified researchers for reviewed research
triggered the update to this PTA. Please also indicate
projects.
if the PTA is being updated as part of its annual
review.

B. What is the technology or format used for
the Project, Program or System?
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.

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

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 IT System (National Park Service Research Permit
and Reporting System)
___ New Project or Program
X Website https://irma.nps.gov/RPRS/Home
___ Web Form, Survey or Information Collection
___ Third-Party Website
___ Social Media Application
___ SharePoint
___ Mobile Application
___ Closed Circuit Television (CCTV)
___ Paper-based Collection
___ Other: Describe.
X Yes: Please describe.
An application form and a permit form.
___ No

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 has reviewed and approved the information
collection requirements associated with the NPS’
application and reports for paleontological permits
(OMB Control Number 1024–0236; Current Expiration
Date: 09/30/2023)
___ No
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U.S. Department of the Interior

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 – PII for Government Users
(NPS employees and other NPS badged contractors and
volunteers) is required for authentication, account
management and logging purposes. NPS users use their
government issued Personal Identity Verification (PIV)
card authenticated through the Enterprise Active
Directory (AD).”

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).

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

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.

This system contains paleontological resources use permit
applications; documents associated with the bureau or office
decision on a permit; documents associated with the
management of the permits, including records of appeals of
bureau or office decisions; and other records necessary to
manage the permitting process and permit-related bureau or
office administrative records.
The system also contains information on permit numbers,
locations of the paleontological site, locality numbers, types,
and purposes of the proposed activity, reports of results of
permitted activities, and locations and transfers of collections
made under a permit. These records may contain the following
information: 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

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U.S. Department of the Interior

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
record related to the implementation of provisions related to
civil penalties under the PRPA.
X Yes: Please describe.

Records are retrieved by the individual’s name
(permittees or researchers), 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.

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

F. Does this Project, Program or System
receive or share PII with any other internal
DOI programs or systems?

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

Indicate whether PII will be shared with or from
internal organizations within DOI.

May be shared with other Bureaus as part of joint
research.
___ No

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U.S. Department of the Interior

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.

“In addition to those disclosures generally permitted
under 5 U.S.C. 552a(b) of the Privacy Act, all or a
portion of the records or information maintained in this
system may be disclosed to authorized entities outside
DOI for purposes determined to be relevant and
necessary as a routine use pursuant to 5 U.S.C. 52a(b)(3)
as indicated in the INTERIOR/DOI-20, Paleontological
Resources Preservation System - 84 FR 52530 (October
2, 2019) SORN.
The System Owners/Managers maintain an accounting of
disclosures of information made to third parties. The
System Owners/Managers use the DI-3710 Disclosure
Accounting form and ensure the accounting of
disclosures is maintained for the life of the record in
accordance with the records retention policy.”
___ No

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.

___ Yes: Please describe applicable information
sharing agreement(s) in place.

X No

Section 4. PTA Review and Recommendation
Question

Response

Privacy Compliance Determination:

_X_ PTA is sufficient at this time
___ Privacy Impact Assessment (PIA) required
___ Adapted PIA required
___ System of Records Notice (SORN) required

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.

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U.S. Department of the Interior

Bureau Associate Privacy Officer Comments:
Provide comments or additional guidance on privacy
compliance requirements.

Associate Privacy Officer Name:

___ 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
___ Refer for Security Compliance Assessment
___ Refer for Information Collection Clearance Review
___ Refer for Records Review
___ Other: Describe.
RPRS is a single data system which is served through a
central internet website and hosted within the NPS
Integrated Resource Management Application (IRMA),
which provides resource information to parks, partners,
and the public. IRMA has a PIA that includes RPRS as a
subsystem in it. The PIA was completed on January 20,
2021. https://www.doi.gov/privacy/pia#NPS
FELIX URIBE

Felix Uribe
Bureau/Office:
Date:

Digitally signed by Felix Uribe
Date: 2022.03.09 12:31:08
-05'00'

NATIONAL PARK SERVICE
3/4/2022
DOI Privacy Office Comments

N/A.

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