Privacy Threshold Analysis (PTA)

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 1 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
This form is used to determine whether
a Privacy Impact Assessment is required.

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under
the E-Government Act of 2002 and the Homeland Security Act of 2002.
Please complete this form and send it to your component Privacy Office. If you do not have a component
Privacy Office, please send the PTA to the DHS Privacy Office:
Rebecca J. Richards
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703-235-0780

PIA@dhs.gov

Upon receipt from the component Privacy Office, the DHS Privacy Office will review this form. If a PIA
is required, the DHS Privacy Office will send you a copy of the Official Privacy Impact Assessment Guide
and accompanying Template to complete and return.
A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy,
on DHSConnect and directly from the DHS Privacy Office via email: pia@dhs.gov, phone: 703-235-0780.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review: October 8, 2010
Name of Project: OMB Collection 1660-0015, Application Forms and Instructions for
(C)LOMAs and (C)LOMR-Fs to National Flood Insurance Program Maps
System Name in TAFISMA:
Name of Component: Federal Emergency Management Agency
Name of Project Manager: Ms. Ava Hammond
Email for Project Manager: Ava.Hammond@dhs.gov
Phone Number for Project Manager: (202) 646-3276
Type of Project:
Information Technology and/or System. 
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
Other:



The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note: for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed for
potential privacy impact.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 3 of 7
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The Department of Homeland Security’s Federal Emergency Management Agency (FEMA)
administers the National Flood Insurance Program (NFIP) and maintains the maps that
depict flood hazard information. The NFIP regulations Section 44 CFR 65 and 70 outline the
data that must be submitted by an owner or lessee of property who believes his/her property
has been incorrectly included in a Special Flood Hazard Area (SFHA). In order to remove an
area from a SFHA, the owner or lessee of the property must submit scientific or technical
data demonstrating that the area is “reasonably safe from flooding” and not in the SFHA.
FEMA Form MT-1 “Application Forms for Conditional Letters of Map Amendment (CLOMAs), Final
Letters of Map Amendment (LOMAs), Letters of Map Revision Based on Fill (LOMR-Fs), and
Conditional Letters of Map Revision Based on Fill (CLOMR-Fs)” supplements the general information
requirements in the NFIP regulations and establishes an organized, systematic approach to
collect data needed to request removal from a SFHA.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated: December 31, 2007
Previous forms collection expired in September of 2007; therefore new forms had to be
submitted to OMB for approval. New forms were approved in December of 2007.

3.

From whom do you collect, process, or retain information on: (Please check all that apply)
DHS Employees.
Contractors working on behalf of DHS.
The Public.
The System does not contain any such information.

4.

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

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 4 of 7
legal authority to do so:

5.

What information about individuals could be collected, generated or retained?
Since the applicants are applying for a letter/determination from DHS-FEMA, they are
required to provide their name, address and telephone number (if available) so that all
correspondence can be sent to them. Some requests require a fee, therefore applicants may
submit payment by check or credit card. Applicants are also required to sign the MT-1 form.

6.

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.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems1?
No.
Yes.
Please list:

8.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.

1

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 TAFISMA.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 5 of 7
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 6 of 7

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: October 21, 2010
Name of the DHS Privacy Office Reviewer: Rebecca J. Richards
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.
National Security System.
Legacy System.
HR System.
Rule.
Other:
Determination
PTA 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: Mapping Information Platform (MIP)
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/FEMA/NFIP/LOMA-1
New SORN is required.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10, 2010
Page 7 of 7
DHS PRIVACY OFFICE COMMENTS The MIP PIA is in the process of being revised to incorporate
changes to NFIP flood maps. The FEMA LOMA SORN is being revised to include all types of flood map
changes and renamed to reflect coverage of all flood map changes.