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 10th, 2009
Page 1 of 7
PRIVACY THRESHOLD ANALYSIS (PTA)

CONTACT LISTS
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, 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 DHSOnline 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 10th, 2009
Page 2 of 7
PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: February 6, 2012
NAME of Project: Post Construction Elevation Certificate and Floodproofing Certificate
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Mary Ann Chang
Email for Project Manager: mary.chang@dhs.gov
Phone number for Project Manger: (703) 605-0421
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other: Information Collection

∗

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
•“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 10th, 2009
Page 3 of 7
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The National Flood Insurance Program (NFIP) has developed the Elevation
Certificate and Floodproofing Certificate.
The two certificates are used in
conjunction with the flood insurance application in order to properly rate Post-FIRM
structures in Special Flood Hazard Areas (44 CFR 61.7, 61.8) for flood insurance.
Post-FIRM structures are those buildings constructed after publication of the Flood
Insurance Rate Map (FIRM) for the community. Flood insurance may be purchased
either directly from FEMA (NFIP Direct) through a licensed insurance agent/broker
or from a private sector insurance company participating the FEMA Write-YourOwn Program. Upon completion of the Elevation Certificate by a licensed surveyor
or the completion of the Floodproofing Certificate by an architect or engineer, the
certificates are provided to the NFIP Direct Servicing Agent (NFIP Direct) by the
property owner's insurance agent (or insurance broker) along with an application for
flood insurance. The certificates are maintained by the NFIP Direct. These form may
also be used by insurance companies (such as Nationwide) that participate in the
Write-Your-Own Program; however, the insurance company collects and maintains
the forms for their records and they are not sent to or collected by FEMA. FEMA
collection of the Elevation Certificate and Floodproofing Certificate through it's NFIP
Direct process is strictly paper based and is part of information collection OMB No.
1660-0008.

2.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed: January 1, 1981
Date last updated: April 1, 2009
Changes made were to clarify the instructions for completeing the form and
to ask for the required information in a clearer manner.

3.

Is the information collected directly from the individuals seeking information from the
Department or working collaboratively with the Department on various projects?
Yes.
No. Please describe the information source and collection method.

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 10th, 2009
Page 4 of 7
4.

Does the individual have the option to decline submitting the information collected?
Yes.
No.

5.

Is the information collected limited to non-sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.

6.

What information about individuals could be collected, generated or retained?
Property Owner or Owner's Representative:
Name
Property Address
Signature
Telephone Number
Surveyor, Engineer, or Architect:
Name
License Number (Surveyor, Engineer, or Architect certification)
Title
Affiliate Organization
Organization Address
Signature
Telephone Number
Community Official (Mayor or County Executive):
Name
Title
Signature
Telephone Number

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 10th, 2009
Page 5 of 7
7.

Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No.

8.

With whom could the information be shared?
The NFIP Direct Serving Agent (contracted by FEMA to issue NFIP policies) does not
share this information with outside sources.
Property owners may choose to submit the certificates to local or tribal government
offices for purposes not related to obtaining flood insurance. However, any information
transferred by the property owner is not collected by FEMA. Likewise, property owners
may choose to submit the certificates along with an application for flood insurance when
obtaining flood insurance from a private sector insurance company participating in the
NFIP Write-Your-Own Program. FEMA does not collect or maintain these certificates;
they are maintained in the private companies' files.

9.

Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
No.

10.

Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?
No.
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 10th, 2009
Page 6 of 7
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: February 15, 2012
NAME of the DHS Privacy Office Reviewer: Brian E. Anderson
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: Information Collection
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: DHS/ALL-PIA 006 General Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/FEMA-003 - National Flood
Insurance Program Files and DHS/FEMA/NFIP/LOMA-1 - National Flood Insurance
Program (NFIP) Letter of Map Amendment (LOMA) DHS/ALL-002 Mailing and
Other LIsts
A 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 10th, 2009
Page 7 of 7
DHS PRIVACY OFFICE COMMENTS
DHS/FEMA-003 and DHS/FEMA/NFIP/LOMA-1 SORNS provide explicit coverage of
these individuals. The use of PII is consistent with DHS/ALL-PIA 006 General
Contact Lists.