Federal Subsistence Management System PTA

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:

Federal Subsistence Management System

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:

Office of the Secretary

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

C. Program or Office:

Office of Subsistence Management

Provide the name of the program or office within the
bureau/office.

D. Project/Program Manager or System
Owner:

Name: Derek Hildreth

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

Title: Program Analyst/Subsistence Data Coordinator
Phone: 907-786-3877
E-mail: dhildreth@ios.doi.gov

E. Routing Information:

___ 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.

_X_ Updated PTA
Date of Submission: October 25, 2024

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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

The Federal Subsistence Management Program is a
multi-agency effort to provide the opportunity for a
subsistence way of life by rural Alaskans on Federal
Please describe the project or program, including any
public lands and waters while maintaining healthy
background information to help understand the project, populations of fish and wildlife. Subsistence fishing and
program, or system. If this is an updated PTA, please
hunting provide a large share of the food consumed in
describe the changes that triggered the update to this
rural Alaska. The information is used to monitor some
PTA. Please also indicate if the PTA is being updated
of the subsistence harvests of moose, caribou, deer,
as part of its annual review.
bear, sheep, goat, and fish by rural Alaskans; to collect
biological information; and to monitor activities of take,
trade, and transport of parts.
The Federal Subsistence Board (Board) is an entity
jointly established by the Secretaries of the Interior and
Agriculture to administer the subsistence taking and
uses of fish and wildlife on public lands in Alaska. The
OSM provides substantial administrative support to the
Board pursuant to its governing regulations at 50 C.F.R.
part 100 (Interior) and 36 C.F.R. part 242 (Agriculture).
Testimony at Federal Subsistence Board (Board)
meetings and public comment meetings is recorded
electronically, transcribed, stored for use in regulatory
proposals, and publicly available.
With the enactment of the Department of the Interior's
(Department) 2024 appropriations, Congress approved a
transfer of OSM to the Office of the Secretary.
Consistent with this guidance and in recognition of the
elevation of Tribal sovereignty and additional
efficiencies to be gained, the
Department has determined to move OSM from FWS to
the Office of AS-PMB. This proposal also responded to
the concerns and input of Alaska Native communities
and people-many of whom rely on subsistence
use-and to the need to enhance program operations for
all federally qualified subsistence users particularly in
the face of a changing climate.
This transfer is issued under the authority of title VII of
the Alaska National Interest Lands Conservation Act, 16
U.S.C. §§ 3111-3126; regulations at 36 C.F.R. part 242
and 50 C.F.R. part 100; and sections 2 and 5 of
Reorganization Plan No. 3 of 1950 (64 Stat 1262), as
amended.
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U.S. Department of the Interior

The records are used by biologists in the Bureau of Land
Management, National Park Service, Office of
Subsistence Management, the U.S. Fish and Wildlife
Service, and the U.S. Forest Service.

B. What technology or format is used for the
Project, Program, or System?
Select all types of technology or sources that apply to
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.

The program is currently undergoing modernization to
make the forms and applications available electronically
as well as on paper.
_x_ IT System
___ New Project or Program
_x_ Website
_x_ Web Form, Survey or Information Collection
___ Third-Party Website
___ Social Media Application
___ SharePoint
___ Mobile Application
___ Closed Circuit Television (CCTV)
_x__ Paper-based Collection
_x_ Other: Online Permit Applications.
_x__ Yes: Please describe.
The application form (NOMB Control No. 1018-0075
Expires 06/30/2026) for a harvest permit is completed by
agency staff or volunteer permit issuers (tribal and
community leaders) who assist with the issuing of
permits either electronically or manually. In addition, a
harvesting individual is required to return a completed
harvest report to the issuing field office by mail, email,
telephone, fax, or hand-delivery.
___ No
__x_ Yes: Please provide the status of any information

D. Is Office of Management and Budget
(OMB) approval required for the collection?

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

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

OMB Control No. 1018-0075 Expires 06/30/2026. The FWS
forms are currently being modified into DI Forms.

___ No

Section 3. Personally Identifiable Information
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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 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? What is your authority to
collect this information; e.g., Endangered
Species Act, Migratory Bird Treaty Act, etc.
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
_x__ Other: Describe: Volunteers.
___ This project, program, or system does not collect,
maintain, or process PII.

From permit applicants/holders and harvesters
• Name
• Birth Date
• Resident Community
• Personal Email Address
• Home/Work/Cell Telephone Number
• Mailing Address
• Residence Physical Location.
• Proof Of State Residence
• Proof Of Physical Location of Residence
• Permit Number
• The amount of harvest
• The species of harvest
• The date of harvest
• The location of the harvest
• Number of days attempting to harvest.
• The mode of transportation to the harvest
• The actions taken for delinquent harvest report
information.
• Notes on reminder letters or notices
• Restriction of harvest start and end dates.
• Notes related to the collection or resolution of the
harvest.
From board applicants and nominees (made up of
Federal government employees and members of the
public):
Applicant/nominee full name, home, work, fax numbers,
birthdate, mailing and email address; References' full
name, home, work, fax numbers, email address,

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Question

Response
organization, organization address, and general
information about serving on board.
Authority: ANILCA (Alaska National Interest Lands
Conservation Act, Title 50 Chapter I Subchapter H Part
100).
Harvest statistics are conjoined, with PII redacted from
the records, to perform analysis and report development
and shared with the Board to assist them with regulatory
decision-making.

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

__x_ Yes: Please describe.
Identifiers:
• Name
• Address
• Phone number.
• Email
• Subsistence Permit Number.
• State Hunting/Trapping License number.
Retrieval method
• Electronically (Database).
• From Paper Records.
___ No

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

___ Yes: Please provide the title, date, and Federal
Register citation.

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.

__X_ No:

E. Does the Project, Program, or System
collect or use Social Security Numbers
(SSNs)?

___ Yes: Please provide the legal authority for the
collection of SSNs and describe the uses of the SSNs
within the Project, Program, or System.

List the statutory and regulatory authority and
Executive Orders that authorize the collection or use
of SSNs to meet an official program mission or goal.

_X__ No

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

_x__ Yes:

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Question

Response

PII with other Bureaus, and if so who, how,
and what for?

In addition to OSM, data is collected by three other
Department of Interior branches. This data is compiled
and housed in agency servers in Denver Colorado and is
available to these agencies electronically through this
system:

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

•
•
•

Bureau of Land Management
National Park Service
US Fish and Wildlife Service

___ No
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 the
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.

The system receives or shares PII with a branch of the
Department of Agriculture:

PII is composed of name, address, phone, permit number,
state licenses, harvest identification, and statistics.

U.S. Forest Service.
Volunteer permit issuers (tribal and community leaders)
have access to the permitting PII because they assist with
the issuing of permits, filling out applications, and
distributing permits and harvest report postcards.
___ No

H. Is this external sharing under new or
existing information-sharing agreements
(Memorandum of Understanding,
Memorandum of Agreement, Letters of
Intent, etc.)?

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

_X_ No

Information-sharing agreements are generally
documented in Memorandums of Understanding,
Memorandums of Agreement, Letters of Intent, or
other documents, and outline them to ensure all
parties understand and adhere to the mutually
established terms of the agreement.

Section 4. PTA Review and Recommendation
Question

Response

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

Privacy Compliance Determination:
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.

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

___ PTA is sufficient currently.
_X__ Privacy Impact Assessment (PIA) required.
___ Adapted PIA required.
_X__ System of Records Notice (SORN) required.
___ Notice of Proposed Rulemaking/Final Rule required.
___ Computer Matching Notice required.
___ Computer Matching Agreement required.
_X__ Privacy Act Statement required.
___ Privacy Notice required.
___ Specialized role-based training required.
_X__ 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.
__X_ Other: Describe. 508 Compliance required.

IT System needs a PIA because it collects and maintains
PII from members of the public. SORN also needed
because records about individuals are retrieved by a
unique personal identifier assigned to the individual.
FWS SORN Permits-21 is not sufficient as system owner
and Privacy Act system manager is OS/PMB. Privacy
Act statements referencing the correct SORN are needed
on the DI Forms. Information sharing agreement needed,
because PII is shared with external non-DOI entity.

Associate Privacy Officer Name:

ADRIENNE BROOKS-HILL

Bureau/Office:

OACIO

Date:

October 29, 2024

Digitally signed by ADRIENNE BROOKS-HILL
Date: 2024.10.29 14:28:31 -04'00'

DOI Privacy Office Comments

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