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
Version number: 03-2020
Page 1 of 11

PRIVACY THRESHOLD ANALYSIS (PTA)

This form will be used to determine whether a Privacy Impact Assessment (PIA), System of Records Notice
(SORN), or other privacy compliance documentation is required under the E-Government Act of 2002, the
Homeland Security Act of 2002, the Privacy Act of 1974, or DHS policy.
Please complete this form and send it to your Component Privacy Office. If you are unsure of your
Component Privacy Office contact information, please visit https://www.dhs.gov/privacy-office-contacts.
If you do not have a Component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
DHS Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717

PIA@hq.dhs.gov

Your Component Privacy Office will submit the PTA on behalf of your office. Upon receipt from your
Component Privacy Office, the DHS Privacy Office will review this form. If a PIA, SORN, or other privacy
compliance documentation is required, your Component Privacy Office, in consultation with the DHS
Privacy Office, will send you a copy of the template to complete and return.
For

more

information

about

the

DHS

Privacy

compliance

process,

please

see

https://www.dhs.gov/compliance. A copy of the template is available on DHS Connect at
http://dhsconnect.dhs.gov/org/offices/priv/Pages/Privacy-Compliance.aspx or directly from the DHS
Privacy Office via email: PIA@hq.dhs.gov or phone: 202-343-1717.

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
Version number: 03-2020
Page 2 of 11

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

National Initiative for Cybersecurity Careers and Studies (NICCS) Training
Catalog Batch Data

Component or
Office:

Cybersecurity and
Infrastructure Security Agency
(CISA)

Office or
Program:

Office of the Chief Learning
Officer (OCLO)

FISMA Name (if
applicable):

N/A

FISMA
Number (if
applicable):

N/A

Program

Project or
program
status:

Operational

June 4, 2012

Pilot launch
date:

December 21, 2012

N/A

Pilot end date:

March 14, 2016

Choose an item.

Expected
ATO/ATP/OA
date (if
applicable):

Click here to enter a date.

Type of Project or
Program:
Date first
developed:
Date of last PTA
update
ATO Status (if
applicable):1

PROJECT, PROGRAM, OR SYSTEM MANAGER
Name:

Shannon Nguyen

Office:

OCLO

Title:

Program Manager

Phone:

202-657-3298

Email:

shannon.nguyen@hq.dhs.gov

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)

1

Name:

Feda Handac

Phone:

678-428-9203

Email:

feda.handac@associates.cisa.dhs.gov

The DHS OCIO has implemented a streamlined approach to authorizing an Authority to Operate (ATO), allowing for rapid deployment of new
IT systems and initiate using the latest technologies as quickly as possible. This approach is used for selected information systems that meet the
required eligibility criteria in order to be operational and connect to the network. For more information, see
http://dhsconnect.dhs.gov/org/comp/mgmt/ocio/ciso/CISO%20ALL%20Documents/Authority%20to%20Proceed%20Memo%20Phase%20II.pdf.

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
Version number: 03-2020
Page 3 of 11

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: New PTA
This new PTA is being conducted for the Cybersecurity and Infrastructure Security Agency (CISA)
Office of the Chief Learning Officer (OCLO) National Initiative for Cybersecurity Careers and Studies
(NICCS) Training Catalog Batch Data. This form allows organization and academic institutions to
provide course-specific technical information to NICCS regarding how their training courses map to the
National Initiative for Cybersecurity Education (NICE) Workforce Framework for Cybersecurity (NICE
Framework) Specialty Areas. This PTA replaces the legacy NICCS PTA2, which is no longer valid as the
information previously covered by the legacy PTA is now covered by PTAs respective to the individual
collections of information, and not just one programmatic PTA.
NICCS is a public-facing website, available at niccs.cisa.gov, created to provide the general public with
the resources necessary to expand their knowledge of cybersecurity through training and education
courses. . The courses are listed in the NICCS Education and Training Catalog, available at
niccs.cisa.gov/education-training/catalog, serves asa central location for cybersecurity professionals to
find cybersecurity-related courses online and in person..
Organizations or academic institutions interested in listing courses with NICCS must first complete a
vendor vetting process3 in order to be considered for inclusion in the NICCS Education and Training
Catalog. Once approved, organizations and academic institutions are asked to provide technical
information (“training catalog batch data”) to NICCS regarding how their training courses map to the
National Initiative for Cybersecurity Education (NICE) Workforce Framework for Cybersecurity (NICE
Framework) Specialty Areas. Course mapping to these Specialty Areas allows users to tailor their
individual coursework and is dependent upon the training catalog batch data to do so. The training
catalog batch data is technical in nature, is not privacy sensitive, and does not include personally
identifiable information. The training catalog batch data is submitted to the CISA NICCS Supervisory
Office (SO) for review. Once approved, the organization/academic institution’s course is listed in the
NICCS Education and Training Catalog.

☒ This project does not collect, collect, maintain,
2. From whom does the Project, Program,
or System collect, maintain, use, or
disseminate information?
Please check all that apply.

use, or disseminate any personally identifiable
information4

☐ Members of the public
☐ U.S. Persons (U.S citizens or lawful
permanent residents)

See PTA, CISA – NICCS, 20190722, PRIV Final.pdf
See PTA, CISA – Vendor Vetting Form
4
DHS defines personal information as “Personally Identifiable Information” or PII, 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 PII” is PII, 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 PII are treated the same.
2
3

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
Version number: 03-2020
Page 4 of 11

☐ Non-U.S. Persons
☐ DHS Employees/Contractors (list Components):
Click here to enter text.

☐ Other federal employees or contractors (list
agencies): Click here to enter text.

☒ No
2(a) Is information meant to be collected
from or about sensitive/protected
populations?

☐ 8 USC § 1367 protected individuals (e.g., T, U,
VAWA)5

☐ Refugees/Asylees
☐ Other. Please list: Click here to enter text.

3. What specific information about individuals is collected, maintained, used, or
disseminated?
Specific information about individuals is not collected, maintained, used or disseminated. Training
Providers are asked to provide technical information regarding how their training courses map to the
National Initiative for Cybersecurity Education (NICE) Workforce Framework for Cybersecurity (NICE
Framework) Specialty Areas. Below is the information provided and a brief description of each.
COURSE-SPECIFIC TECHNICAL INFORMATION PROVIDED TO NICCS
Column Name

5

Required

Description

tccid

NO

The NICCS-provided course id of the record.

name

YES

The title of the training course.

provider

YES

The name of the organization, as it will display on the NICCS
website.

tcccatnbr

NO

The Catalog Number of the training course.

tcclocalnbr

NO

The Provider-specified Course ID

tcccae

NO

Identifying providers who have been recognized as NCAE-C
Designated Institution.

tcccourl

YES

The course URL of the training course.

description

YES

Training course description

tccprereq

YES

Training course prerequisites

This involves the following types of individuals: T nonimmigrant status (Victims of Human Trafficking), U nonimmigrant status (Victims of
Criminal Activity), or Violence Against Women Act (VAWA). For more information about 1367 populations, please see: DHS Management
Directive 002-02, Implementation of Section 1367 Information Provisions, available at
http://dhsconnect.dhs.gov/org/comp/mgmt/policies/Directives/002-02.pdf.

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
Version number: 03-2020
Page 5 of 11
tccproflvl

YES

Training course overall proficiency level

tcctrainpur

YES

Training course training purposes

tccaudience

YES

Training course audiences

tccobjective

YES

Training course objectives

tccdelmethod

YES

The course delivery method of the training course.

tccspecarea

YES

The specialty area of the training course

tcccourseloc

NO

A JSON-formatted list of addresses where the training course is
offered.

softdelete

NO

A field to indicate the course should be unpublished from the
NICCS training catalog.

tcccomp

YES

The competency area of the training course

tccworkrole

YES

The work role of the training course

3(a) Does this Project, Program, or System collect, maintain, use, or disseminate Social Security
numbers (SSN) or other types of stand-alone sensitive information?6 If applicable, check all
that apply.

☐ Social Security number

☐ Social Media Handle/ID

☐ Alien Number (A-Number)

☐ Biometric identifiers (e.g., FIN, EID)ion

☐ Tax Identification Number
☐ Visa Number

☐ Biometrics.7 Please list modalities (e.g.,
fingerprints, DNA, iris scans): Click here to

☐ Passport Number

enter text.

☐ Other. Please list: Click here to enter text.

☐ Bank Account, Credit Card, or other
financial account number
☐ Driver’s License/State ID Number
3(b) Please provide the specific legal basis
for the collection of SSN:

6

N/A

Sensitive PII (or sensitive information) is PII that if lost, compromised, or disclosed without authorization, could result in substantial harm,
embarrassment, inconvenience, or unfairness to an individual. More information can be found in the DHS Handbook for Safeguarding Sensitive
Personally Identifiable Information, available at https://www.dhs.gov/publication/handbook-safeguarding-sensitive-personally-identifiableinformation.
7
If related to IDENT/HART and applicable, please complete all Data Access Request Analysis (DARA) requirements. This form provides
privacy analysis for DHS’ IDENT, soon to be HART. The form replaces a PTA where IDENT is a service provider for component records. PRIV
uses this form to better understand how data is currently shared, will be shared and how data protection within IDENT will be accomplished.
IDENT is a biometrics service provider and any component or agency submitting data to IDENT is a data provider.

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
Version number: 03-2020
Page 6 of 11

3(c) If the SSN is needed to carry out the functions and/or fulfill requirements of the Project,
System, or Program, please explain why it is necessary and how it will be used.
N/A
3(d) If the Project, Program, or System requires the use of SSN, what actions are being taken to
abide by Privacy Policy Instruction 047-01-010, SSN Collection and Use Reduction,8 which
requires the use of privacy-enhancing SSN alternatives when there are technological, legal, or
regulatory limitations to eliminating the SSN? Note: even if you are properly authorized to collect
SSNs, you are required to use an alternate unique identifier. If there are technological, legal, or
regulatory limitations to eliminating the SSN, privacy-enhancing alternatives should be taken, such as
masking, truncating, or encrypting the SSN, or blocking the display of SSNs in hard copy or digital
formats.
N/A

☐ By a unique identifier.9 Please list all unique
4. How does the Project, Program, or
System retrieve information?

5. What is the records retention
schedule(s) for the information
collected for each category type (include
the records schedule number)? If no
schedule has been approved, please
provide proposed schedule or plans to
determine it.
Note: If no records schedule is in place or are unsure

identifiers used:
Click here to enter text.
☒ By a non-unique identifier or other means. Please
describe: Information is retrieved using the catalog
number of the training course.

General Records Schedule 3.1- Item 051
General Technology Management Records: Data
Administration Records.

of the applicable records schedule, please reach out to
the appropriate Records Management Office.10

5(a) How does the Project, Program, or
System ensure that records are
disposed of or deleted in accordance
with the retention schedule (e.g.,
technical/automatic purge, manual audit)?

8

CISA has worked with the National Archives and
Records Administration (NARA) to identify an
approved records retention schedules and policy for
its systems. Records will be purged from the DHS
database after five years, per DHS existing policy.
CISA cybersecurity analysts are also required to
review all data collected and determine if it is
necessary to analyze or understand the cybersecurity

See https://www.dhs.gov/publication/privacy-policy-instruction-047-01-010-ssn-collection-and-use-reduction.
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.
10
See http://dhsconnect.dhs.gov/org/comp/mgmt/ocio/IS2O/rm/Pages/RIM-Contacts.aspx
9

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
Version number: 03-2020
Page 7 of 11

threat. CISA information handling guidelines and
operating procedures provide the procedures for the
collection processing, retention, and dissemination
of data.
6. Does this Project, Program, or System
connect, receive, or share PII with any
other DHS/Component projects,
programs, or systems?11

☒ No.

7. Does this Project, Program, or System
connect, receive, or share PII with any
external (non-DHS) government or
non-government partners or systems?

☒ No.

8. Is this sharing pursuant to new or
existing information sharing agreement
(MOU, MOA, LOI, RTA, etc.)? If
applicable, please provide agreement as
an attachment.
9. Does the Project, Program, or System
or have a mechanism to track external
disclosures of an individual’s PII?

☐ Yes. If yes, please list:

☐ Yes. If yes, please list:
Choose an item.
Please describe applicable information sharing
governance in place: N/A

☒ No. What steps will be taken to develop and
maintain the accounting: N/A

☐ Yes. In what format is the accounting
maintained:

10. Does this Project, Program, or System
use or collect data involving or from
any of the following technologies:

☐ Social Media
☐ Advanced analytics12
☐ Live PII data for testing
☒ No

11. Does this Project, Program, or System
use data to conduct electronic searches,
queries, or analyses in an electronic
database to discover or locate a
predictive pattern or an anomaly
indicative of terrorist or criminal
activity on the part of any individual(s)

11

☒ No.
☐ Yes. If yes, please elaborate:

PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes. Often, these systems are listed
as “interconnected systems” in IACS.
12
The autonomous or semi-autonomous examination of Personally Identifiable Information using sophisticated techniques and tools to draw
conclusions. Advanced Analytics could include human-developed or machine-developed algorithms and encompasses, but is not limited to, the
following: data mining, pattern and trend analysis, complex event processing, machine learning or deep learning, artificial intelligence, predictive
analytics, big data analytics.

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
Version number: 03-2020
Page 8 of 11

(i.e., data mining)?13 This does not
include subject-based searches.
11(a) Is information used for research,
statistical, or other similar purposes?
If so, how will the information be deidentified, aggregated, or otherwise
privacy-protected?

☒ No.

12. Does the planned effort include any

☒ No.

interaction or intervention with human
subjects14 via pilot studies, exercises,
focus groups, surveys, equipment or
technology, observation of public
behavior, review of data sets, etc. for
research purposes

☐ Yes. If yes, please elaborate:

☐ Yes. If yes, please reach out to the DHS
Compliance Assurance Program Office (CAPO) for
independent review and approval of this effort.15

13. Does the Project, Program, or System
provide role-based or additional
privacy training for personnel who
have access, in addition to annual
privacy training required of all DHS
personnel?

☒ No.

14. Is there a FIPS 199 determination?16

☒ No.

☐ Yes. If yes, please list:

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

☐ Low ☐ Moderate ☐ High ☐ Undefined

13

Is this a program involving pattern-based queries, searches, or other analyses of one or more electronic databases, where—
(A) a department or agency of the Federal Government, or a non-Federal entity acting on behalf of the Federal Government, is conducting
the queries, searches, or other analyses to discover or locate a predictive pattern or anomaly indicative of terrorist or criminal activity on the part of
any individual or individuals;
(B) the queries, searches, or other analyses are not subject-based and do not use personal identifiers of a specific individual, or inputs
associated with a specific individual or group of individuals, to retrieve information from the database or databases; and
(C) the purpose of the queries, searches, or other analyses is not solely—
(i) the detection of fraud, waste, or abuse in a Government agency or program; or
(ii) the security of a Government computer system.
14
Human subject means a living individual about whom an investigator conducting research: (1) obtains information or biospecimens through
intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimens; or (2) obtains, uses, studies, analyzes,
or generates identifiable private information or identifiable biospecimens.
15
For more information about CAPO and their points of contact, please see: https://www.dhs.gov/publication/compliance-assurance-programoffice or https://collaborate.st.dhs.gov/orgs/STCSSites/SitePages/Home.aspx?orgid=36. For more information about the protection of human
subjects, please see DHS Directive 026-04: https://www.dhs.gov/sites/default/files/publications/mgmt/general-science-and-innovation/mgmtdir_026-04-protection-of-human-subjects_revision-01.pdf.
16
FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal Information and
Information Systems and is used to establish security categories of information systems.

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
Version number: 03-2020
Page 9 of 11

Integrity:

☐ Low ☐ Moderate ☐ High ☐ Undefined
Availability:

☐ Low ☐ Moderate ☐ High ☒ Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Donna Hellberg

Date submitted to Component Privacy
Office:

November 14, 2022

Concurrence from other Component
Reviewers involved (if applicable):

Click here to enter text.

Date submitted to DHS Privacy Office:

November 15, 2022

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed,
as well as any specific privacy risks/mitigations, as necessary.
The NICCS program provides an invaluable resource to the cybersecurity industry by making courses and
their training providers available to the public. Once vetted and approved, NICCS program staff ask
training providers to complete a technical mapping of their course to its applicable NICE Framework
Specialty Areas. This process allows users to narrow search results for training courses down to their
desired areas of cybersecurity education and training.
The information collected via NICCS Training Catalog Batch Data is not privacy sensitive and does not
include personally identifiable information.
Separate privacy compliance documentation used in conjunction with the NICCS Training Catalog Batch
Data in which privacy sensitive information is collected. Information submitted on that form is not
maintained on the website but rather in the program’s document repository restricted to program
personnel only. Please see the NICCS Vendor Vetting Forms PTA for more information.

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
Version number: 03-2020
Page 10 of 11

(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Kattina Do

DHS Privacy Office Approver (if applicable):

Schuntel Reddock

Workflow Number:

0023424

Date approved by DHS Privacy Office:

November 17, 2022

PTA Expiration Date

November 17, 2025
DESIGNATION

Privacy Sensitive System:

Program

Category of System:
Determination:

No
If “other” is selected, please describe: Click here to enter text.

☒ Project, Program, System in compliance with full coverage
☐ Project, Program, System in compliance with interim coverage
☐ Project, Program, System in compliance until changes implemented
☐ Project, Program, System not in compliance

PIA:
SORN:

Choose an item.
Click here to enter text.
Choose an item.

Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above, and any further action(s) that
must be taken by Component.
CISA is submitting this PTA to discuss the National Initiative for Cybersecurity Careers and Studies
(NICCS) Training Catalog Batch Data. NICCS is a public-facing website, available at niccs.cisa.gov,
created to provide the general public with the resources necessary to expand their knowledge of
cybersecurity through training and education courses. Organizations or academic institutions interested in
listing courses with NICCS must first complete a vendor vetting process in order to be considered for
inclusion in the NICCS Education and Training Catalog. The training catalog batch data is technical in
nature, is not privacy sensitive, and does not include personally identifiable information. The training
catalog batch data is submitted to the CISA NICCS Supervisory Office (SO) for review. Once approved,
the organization/academic institution’s course is listed in the NICCS Education and Training Catalog.

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
Version number: 03-2020
Page 11 of 11

Specific information about individuals is not collected, maintained, used or disseminated. Training
Providers are asked to provide technical information regarding how their training courses map to the
National Initiative for Cybersecurity Education (NICE) Workforce Framework for Cybersecurity (NICE
Framework) Specialty Areas.
The DHS Privacy Office (PRIV) finds that this program is not privacy-sensitive because PII is not
collected, and therefore a PTA is sufficient at this time.