Privacy Threshold Analysis (PTA)

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
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

[email protected]

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: [email protected], phone: 703-235-0780.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
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: November 13, 2013
NAME of Project: FloodSmart Websites
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Mary Jo Vrem
Email for Project Manager: [email protected]
Phone number for Project Manger: 202-212-4727
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
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, [email protected]
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:
FEMA’s National Flood Insurance Program (NFIP) (42 USC Chapter 50) operates a
marketing and advertising program called FloodSmart to increase awareness of flood
risk and to encourage homeowners, renters, condominium owners, and business
owners to purchase federally-backed flood insurance. FloodSmart is responsible for
two websites that support flood insurance marketing and advertising: The
consumer-facing floodsmart.gov and the insurance industry oriented
agents.floodsmart.gov. The websites collects personally identifiable information (PII)
from both the general public that is interested in flood insurance and by insurance
agents that wish to be contacted by the general public regarding the NFIP
respectively. The PII collected is limited to basic contact-related information.
The Floodsmart websites plays a lead role in connecting the general public with flood
insurance agents and providing information regarding the FEMA NFIP and
beginning the process of purchasing flood insurance policies.
FloodSmart.gov provides general information about flood risk and flood insurance,
including a vast array of resources, educational information, risk assessment tools,
and a means through which the consumer can locate an insurance agent in their area
that sell flood insurance. Visitors to this site can request additional flood insurance
information or have an agent contact them for the purchase of flood insurance
through the FEMA NFIP. Additionally, visitors the this site can request a risk
assessment of a property by providing FEMA with a property address. Floodsmart
uses information from the FEMA Mapping Information Platform (MIP) to provide
flood risk mapping information as it relates to the property. FEMA MIP is currently
covered by the DHS/FEMA/PIA-028 - Mapping Information Platform (MIP) Privacy
Impact Assessment and its associated System of Records Notice.
The general Agents.FloodSmart.gov is designed for the insurance agent to learn
about selling flood insurance, gaining access to training, tools and resources, as well
as the capability to register for the referral program. Agents can provide user
account creation information (first/last name, agency address, agency phone number)
to register on Agents.FloodSmart.gov. Once registered, an agent can access their
registration profile and update contact information.
The production environment and backend database for both websites is owned by
FEMA and will be hosted at a NFIP Virtualized Information Technology Systems
(NVITS) server site as of December 15, 2013
Both websites are designed, developed, and maintained by Blue Water Media
(BWM). BWM’s development environment maintains a copy of the primary
FloodSmart database. BWM’s FloodSmart Development Environment is hosted at a

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 7
secured facility in Greenbelt, MD on a secured, dedicated system for the following
web management usage:

2.

•

Content and functionality changes to FloodSmart.gov files;

•

Content and functionality changes to Agents.FloodSmart.gov files; and

•

Database imports for refreshing the development environment.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed: June 2, 2004
Date last updated: November 15, 2012
Expected "Go Live" date at new NFIP ITS hosting site is 12/15/13).

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.

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?
The following information may be voluntarily collected from or generated on the
general public and flood insurance agents to facilitate contact within the FEMA NFIP

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 7
and for system registration: Name, Address(es), Phone number, Email address, and
Geocode (Latitude and Longitude).
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?
This information is shared with the FloodSmart team and FEMA stakeholders for
reporting purposes.

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, [email protected]
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: December 12, 2013
NAME of the DHS Privacy Office Reviewer: Jameson Morgan
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
A PIA is required
System covered by existing PIA: DHS/ALL/PIA-006 Department of
Homeland Security General Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL-002 - Department of
Homeland Security (DHS) Mailing and Other Lists System; DHS/ALL-004 - General
Information Technology Access Account Records System (GITAARS)
A new SORN is required.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 7
DHS PRIVACY OFFICE COMMENTS
The DHS Privacy Office approves this PTA with coverage under the DHS/ALL/PIA –
006 DHS General Contact Lists PIA; the DHS/ALL – 002 HDS Mailing and Other
Lists System SORN; and the DHS/ALL – 004 DHS General Information Technology
Access Account Records System (GITAARS) SORN.
This system enables member of public to educate themselves about federal flood
insurance programs and contact insurance agents who provide coverage for such
insurance. This system provides members of the public with the ability to contact
insurance providers who voluntarily participate in this system. Information
collection from all parties is voluntary. Information is only collected for the purpose
of account creation and connecting the two participating parties. FEMA must collect
limited PII order to provide this service to members of the public and insurance
agents.
The DHS/ALL/PIA – 006 Contact Lists PIA provides coverage to Floodsmart because
it allows DHS/FEMA to collect a minimal amount of information in order to
distribute information and perform various other administrative tasks, such as those
associated with the Floodsmart system.
The DHS/ALL – 002 Mailing and Other Lists SORN provides coverage to the contact
information provided by members of the public and agents providing insurance
coverage in this system. This system allows DHS to collect and maintain information
on maintaining lists of individuals who attend meetings and for other purposes for
which mailing or contact lists may be created. This SORN provides coverage because
all parties involved are providing contact information in order to be connected with
the other interested party.
The DHS/ALL – 004 GITAARS SORN provides coverage to the general information
submitted by insurance agents in order to create accounts to access the system and
get in contact with interested individuals.