1 

Privacy and Civil Liberties Impact Assessment

for the

Coronavirus Economic Relief for Transportation Services (CERTS) 

Program

November 8, 2021

Reviewing Official 

Timothy H. Skinner

Bureau Privacy and Civil Liberties Officer

Departmental Offices

Department of the Treasury
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Section 1: Introduction

PCLIAs are required for all systems and projects that collect, maintain, or disseminate personally 

identifiable information (PII). The system owner completed this assessment pursuant to Section 208 of 

the E-Government Act of 2002 (“E-Gov Act”), 44 U.S.C. § 3501, Office of the Management and Budget 

(OMB) Memorandum 03-22, “OMB Guidance for Implementing the Privacy Provisions of the EGovernment Act of 2002,” and Treasury Directive 25-07, “Privacy and Civil Liberties Impact Assessment 

(PCLIA),” which requires Treasury Offices and Bureaus to conduct a PCLIA before: (1) developing or 

procuring information technology (IT) systems or projects that collect, maintain or disseminate PII from 

or about members of the public, or (2) initiating a new collection of information that: (a) will be collected, 

maintained, or disseminated using IT; and (b) includes any PII permitting the physical or online 

contacting of a specific individual, if identical questions have been posed to, or identical reporting 

requirements imposed on, 10 or more persons (not including agencies, instrumentalities, or employees of 

the federal government).

It is the policy of the Department of the Treasury (“Treasury” or “Department”) and its Bureaus to 

conduct a PCLIA when PII is maintained in a system or by a project. This PCLIA provides the following 

information regarding the system or project: (1) an overview of its purpose and functions; (2) a 

description of the information collected; (3) a description of the how information is maintained, used, and 

shared; (4) an assessment of whether the system or project is in compliance with federal requirements that 

support information privacy; and (5) an overview of the redress/complaint procedures available to 

individuals who may be affected by the use or sharing of information by the system or project. 

Section 2: System Overview 

Section 2.1: System/Project Description and Purpose

The Coronavirus Economic Relief for Transportation Services (CERTS) Act, Division N, Title IV, 

Subtitle B of the Consolidated Appropriations Act of 2021 is a program providing eligible transportation 

service companies (motorcoach companies; passenger vessel companies; school bus companies; and 

pilotage companies) with resources to help to maintain payroll, rehire employees who may have been laid 

off, and cover applicable overhead and operational expenses. 

Under the program, Treasury will provide up to $2 billion in grants to eligible companies that certify they 

have experienced an annual revenue loss of 25 percent or more as a direct or indirect result of COVID-19. 

CERTS grant funds are primarily to cover payroll costs, but may also be used to cover the acquisition of 

services, equipment, including personal protective equipment and protection measures from COVID-19 

for workers and customers; continued operations and maintenance of existing equipment and facilities; 

rent, leases, insurance, and interest on regular debt service.

Under CERTS, Treasury makes payments directly to the approved applicants which are motorcoach 

companies, passenger vessel companies, school bus companies, and pilotage companies. Funds are 

available until expended. Although most of the transportation service companies that are eligible under 

the program are business entities and not individuals to whom the PCLIA process applies, some of the 

eligible transportation service companies are sole proprietors (an individual who is the sole owner of an 

unincorporated business).
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To access the CERTS Portal and submit an application to Treasury, a company representative first must 

be registered with a username and password through ID.me, a private sector company that provides

identity verification services. The company representative who registers with ID.me will be the point of 

contact to access the CERTS Portal to answer application questions, upload required documents, and 

perform other administrative functions in the portal. ID.me is an approved service provider for Treasury 

and offers a one-time identity verification process to safeguard data and authenticate users prior to 

accessing Treasury systems.

As part of the CERTS verification procedures, Treasury plans to use the Bureau of the Fiscal Service’s

(“Fiscal Service”) existing Account Verification Service (AVS) to verify that the grantees match the 

information provided during the application process. AVS is a service provided by PNC Financial 

Services (PNC) to allow merchants to detect suspicious transactions and prevent fraud. AVS is one of the 

tools that assists the CERTS program in determining whether an otherwise eligible transportation service 

company is legitimate before depositing funds using the account information it provided. Fiscal Service 

may initiate a specific AVS inquiry in accordance with the authorized uses. The Fiscal Service may 

access AVS and upload batch files AVS through an application program interface (API) or through a 

virtual terminal connection method with PNC. After Fiscal Service submits an inquiry, if there is a 

match, the Fiscal Service will receive response data. For purposes of the CERTS program, an eligible 

transportation service company’s name, tax identification number (TIN), bank account number, and 

Routing Transit Number (RTN) are compared with the account information on record at the company’s

bank (the bank to which Treasury will potentially deposit funds under the program). After comparing the 

company’s bank account information with the information in its CERTS application, PNC sends a 

response code back to Fiscal Service indicating the degree to which the information provided by the 

company matches the records on file at its bank. CERTS uses the additional PII collected from applicants 

to verify their identity and their eligibility for the grants. All data collected as part of the CERTS program 

are stored in Treasury Salesforce. Treasury Salesforce has its own PCLIA.

Please check the statement below that applies to your system or project and provide any additional 

information requested. Please read all possible responses before selecting an answer.

1. ☒ A PCLIA is being done for this system for the first time.

2. ☐ This is an update of a PCLIA previously completed and published under this same system or 

project name. The date the earlier PCLIA was published was... 

3. ☐ This is an update of a PCLIA previously completed and published for a similar system or 

project that is undergoing a substantial modification or migration to a new system or project 

name. The name of that previous PCLIA was [Name the PCLIA here] and the date of its 

publication was 1.1.2020 

Section 2.2: Authority to Collect

Federal agencies must have proper authority before initiating a collection of information. The authority is 

sometimes granted by a specific statute, by Executive order (EO) of the President or other authority. The 

following specific authorities authorize CERTS to collect information:

• The Consolidated Appropriations Act, 2021, Division N, Title IV, Subtitle B Section 420, Pub. L. 

No. 116-260 (Dec. 27, 2020) 

The information may also be collected pursuant to a more general requirement or authority. All Treasury 

systems and projects derive general authority to collect information from:
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• 31 U.S.C. 321 – General authorities of the Secretary establish the mission of the Department of 

the Treasury

• 5 U.S.C. 301 – Department regulations for the operations of the department, conduct of 

employees, distribution and performance of its business, the custody, use, and preservation of its 

records, papers, and property.

Section 2.3: Privacy Act Applicability; SORN Requirement 

Under certain circumstances, federal agencies are allowed to exempt a system of records from certain 

provisions in the Privacy Act. This means that, with respect to information systems and papers files that 

maintain records in that system of records, the agency will not be required to comply with the 

requirements in Privacy Act provisions that are properly exempted. If this system or project contains 

records covered by the Privacy Act, the applicable Privacy Act system of records notice(s) (SORNs) 

(there may be more than one) that cover the records in this system or project must list the exemptions 

claimed for the system of records (it will typically say: “Exemptions Claimed for the System” or words to 

that effect). 

Helpful Hint for answering questions in this section and later questions about Privacy Act exemptions: If 

you know there is a SORN covering the PII in this system, the answer is probably “yes.” If the system 

maintains PII, but that PII is not actually retrieved by a personal identified, the answer is “no.” At the 

bottom of the applicable SORN(s), you will find a section that says: “Exemptions Claimed for the 

System.” If the answer is “None” (or anything that indicates no exemptions are claimed): (1) your bureau 

or office does not exempt the system of records from any Privacy Act requirements; and (2) when you are 

asked in this template whether your bureau or office exempts the system of records from certain 

provisions in the Privacy Act, your answer will always be “No.” 

All answers in this section must be provided in the space as instructed after checking the appropriate 

box(es). 

Section 2.3(a) Please check ALL statements below that apply to your system or project and 

provide any additional information requested. Please read all possible responses before selecting an 

answer.

1. ☐ The system or project does not retrieve records about an individual using an identifying 

number, symbol, or other identifying particular assigned to the individual. A SORN is not 

required with respect to the records in this system.

2. ☒ The system or project does retrieve records about an individual using an identifying number, 

symbol, or other identifying particular assigned to the individual. A SORN is required with 

respect to the records in this system. Information about sole proprietors that the CERTS program 

provides to the Fiscal Service for grantee verification processing is covered under 

Treasury/Fiscal Services SORN .002 Payment Records and Treasury Financial Management 

Systems SORN .009. Fiscal Service may initiate a specific inquiry for the verification (using sole 

proprietors’ data) in accordance with the authorized uses. Fiscal Service may access the Service 

through an API, upload batch files, or through a virtual terminal connection method with PNC). 

With respect to CERTS program implementation other than grantee verification (via the Fiscal 

Service), the CERTS program retrieves applicant information by the name of the applicant’s 

point of contact (POC). Retrieval of records by the name of a grantee’s POC is covered by 

Treasury .017 – Correspondence and Contact Information – 81 FR 78266 (Nov. 7, 2016). 

3. ☐ A SORN was identified in the original PCLIA and a determination was made during this 

current PCLIA update that modifications [choose one] ☐ were ☐ were not required to that 
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SORN. [If modifications were made, generally describe them here]. The current applicable 

SORN is: [Provide here the SORN number(s), system of records name(s) and the citation to the 

SORN(s) in the Federal Register.]

4. ☐ A SORN(s) was not identified or required in the original PCLIA, but a determination was 

made during this current PCLIA update that a SORN(s) is now required. The applicable 

SORN(s) is:[Provide here the SORN number(s), system of records name(s) and the citation to the 

SORN(s) in the Federal Register]. 

5. ☒ A SORN was published and no exemptions are taken from any Privacy Act requirements.

TREASURY/Fiscal Service .002—Payment Records. Information about sole proprietors is

covered under Treasury/Fiscal Services SORN .002 Payment Records and Treasury Financial 

Management Systems SORN .009. The rest of the data elements associated with the CERTS 

program are not covered under this SORN. Retrieval of records by the name of a grantee’s POC 

is covered by Treasury .017 – Correspondence and Contact Information – 81 FR 78266 (Nov. 7, 

2016).

6. ☐ Exemptions are claimed from the following Privacy Act provisions in the applicable SORN(s): 

[List here all exemptions taken in the applicable SORN; Hint: it’s at the end of the SORN]: The 

citation to the applicable Notice of Proposed Rulemaking and/or Final Rule is[provide here the 

Federal Register Citation to the NPRM and Final Rule (if a Final Rule was required)]. 

Section 3: Information Collection

Section 3.1: Relevant and Necessary

The Privacy Act requires “each agency that maintains a system of records [to] maintain in its records

only such information about an individual as is relevant and necessary to accomplish a purpose of the 

agency required to be accomplished by statute or by executive order of the President.” 5 U.S.C. § 

552a (e)(1). It allows federal agencies to exempt records from certain requirements (including the 

relevant and necessary requirement) under certain conditions. 5 U.S.C. §552a (k). The proposed 

exemption must be described in a Notice of Proposed Rulemaking (“NPRM”). In the context of the 

Privacy Act, the purpose of the NPRM is to give the public notice of a Privacy Act exemption 

claimed for a system of records and solicit public opinion on the proposed exemption. After 

addressing any public concerns raised in response to the NPRM, the agency must issue a Final Rule. 

It is possible for some, but not all, of the records maintained in the system or by the project to be 

exempted from the Privacy Act through the NPRM/Final Rule process.

Section 3.1(a) Exemption Claimed from this Requirement?

1. ☒ The PII (about sole proprietors and POCs) maintained in this system or by this project is not

exempt from 5 U.S.C. § 552a(e)(1), the Privacy Act’s requirement that an agency “maintain in its 

records only such information about an individual as is relevant and necessary to accomplish a 

purpose of the agency required to be accomplished by statute or by executive order of the 

President.”

2. ☐ The PII maintained in this system or by this project is exempt from 5 U.S.C. § 552a(e)(1), 

because [See Appendix B for a list of acceptable bases for claiming this exemption and cut and 

paste here all that apply]. 

3. ☐ The Privacy Act does not apply because the information is not maintained in a system of 

records as required to trigger this Privacy Act requirement. Nevertheless, the program will only 

collect information required by law. Therefore, the program is actually meeting the relevance and 

necessity standard.
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Section 3.1(b) Continuously Assessing Relevance and Necessity 

1. ☐ The PII in the system is not maintained in a system of records. Therefore, the Privacy 

requirements do not apply. [Explain here what you do to ensure relevance and necessity despite 

the fact that the Privacy Act does not apply]. 

2. ☐ The PII in the system is maintained in a system of records, but the agency exempted these 

records from the relevance and necessity requirement. [Explain here what you do to ensure 

relevance and necessity to the extent possible despite the fact the records are exempt from this 

requirement]. 

3. ☐ The system owner conducted an assessment prior to collecting PII for use in the system or 

project to determine which PII data elements and types (see Section 3.2 below) were relevant and 

necessary to meet the system’s or project’s mission requirements. During this analysis, in

conducting the “relevance and necessity” analysis that is documented in this PCLIA, the system 

owner reevaluated the necessity and relevance of all PII data elements and determined that they 

are still relevant and necessary. Every time this PCLIA is updated, this ongoing assessment will 

be revisited. If it is determined at any time that certain PII data elements are no longer relevant or 

necessary, the system owner will update this PCLIA to discuss how the data element was 

removed from the system and is no longer collected. Note: PII provided 

4. ☒ With respect to PII currently maintained (as of the time this PCLIA is being done) in the 

system or by the project, the PII is limited to only that which is relevant and necessary to meet the 

system’s or project’s mission requirements. During the PCLIA process, the system always 

undergoes a review to ensure the continuing relevance and necessity of the PII used by the 

program. 

5. ☐ With respect to PII maintained in the system or by the project, there is a process in place to 

continuously reevaluate and ensure that the PII remains relevant and necessary. During the 

PCLIA process (including updates), the system always undergoes a review to ensure the 

continuing relevance and necessity of the PII on the system. If a determination is made that 

particular PII is no longer relevant and necessary in between PCLIA updates, this PCLIA will be 

updated at that time. 

Section 3.2: PII and/or information types or groupings

The checked boxes below represent the types of PII maintained in the system or by the project that are 

relevant and necessary for the information system or project to fulfill its mission. PII identified below is 

used by the system or project to fulfill the purpose stated in Section 2.2 above– Authority to Collect. 

Biographical/general information

☒ Name (Point of Contact) ☐ Nationality ☐ Country of Birth 

☐ Age ☐ Citizenship ☐ Immigration Status 

☐ Date of birth ☐ Ethnicity ☐ Alias (including nickname)

☐ Home physical address ☐ Gender ☐ City or County of Birth 

☐ City, State, and Zip Code ☐ Race ☐ Military Service Information

☒ Business phone, cell 

phone, or fax number 

☒ Business e-mail address ☐ Country or city of residence

☐ Other: 

 
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Other information

☐ Resume or curriculum 

vitae

☐ Cubical or office 

number 

☐ Veteran’s preference

☐ Religion/Religious 

Preference

☐ Education Information 

[please describe]

☐ Spouse Information 

☐ Professional/personal 

references or other information 

about an individual’s friends, 

associates or acquaintances.

☐ Contact lists and directories 

(known to contain at least 

some personal information).

☐ Retirement eligibility 

information

☐ Sexual Orientation ☐ Marital Status ☐ Information about other 

relatives.

☐ Group/Organization 

Membership

☐ Information about children ☐ Other: 

Identifying numbers assigned to individuals 

☒ Full Social Security 

number 

☐ Personal device identifiers or 

serial numbers

☐ Vehicle Identification Number 

☐ Truncated Social Security 

Number (e.g., last 4 digits) 

☐ Internet Protocol (IP) 

Address 

☐ Driver’s License Number

☒ Employee Identification 

Number 

☒ Personal Bank Account 

Number 

☐ License Plate Number

☒ Taxpayer Identification 

Number 

☐ Health Plan Beneficiary 

Number 

☐ Professional License Number

☐ File/Case ID Number ☐ Credit Card Number ☐ Passport Number and 

information 

☐ Alien Registration Number ☐ Patient ID Number ☒ Other: Routing Tracking 

Number 

Specific Information/File Types

☐ Taxpayer Information/Tax 

Return Information 

☐ Law Enforcement 

Information 

☐ Security 

Clearance/Background Check 

Information 

☐ Civil/Criminal History 

Information/Police Records 

(obtained from government 

source) 

☐ Civil/Criminal History 

Information/Police Records 

(obtained from commercial 

source) 

☐ Credit History Information 

(government source) 

☐ Protected Information (as 

defined in Treasury Directive 

25-10) 

☐ Credit History Information 

(commercial source)

☐ Bank Secrecy Act Information 

☐ Information provided under 

a confidentiality agreement

☐ Case files ☐ Personnel Files

☒ Business Financial 

Information 

☒ Personal Financial 

Information (e.g., bank account 

information) 

☐ Information subject to the 

terms of an international or other 

agreement

☐ Passport information (state 

which passport data elements 

are collected if not all)

☐ Other: 
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Audit Log and Security Monitoring Information 

☒ User ID assigned to or 

generated by a user of Treasury 

IT

☒ Files and folders accessed by 

a user of Treasury IT

☐ Biometric information used to 

access Treasury facilities or IT

☒ Passwords generated by or 

assigned to a user of Treasury 

IT

☐ Internet or other queries run 

by a user of Treasury IT

☐ Contents of files accessed by a 

user of Treasury IT 

☐ Files accessed by a user of 

Treasury IT (e.g., web 

navigation habits) 

☒ Date and time an individual 

accesses a facility, system, or 

other IT 

☐ Information revealing an 

individual’s presence in a 

particular location as derived from 

security token/key fob, employee 

identification card scanners or 

other IT. 

☐ Public Key Information 

(PKI).

☐ Still photos of individuals 

derived from security cameras. 

☐ Purchasing habits or 

preferences

☐ Internet Protocol (IP) 

Address 

☐ Video of individuals derived 

from security cameras

☐ Commercially obtained 

internet navigation/purchasing 

habits of individuals 

☐ Global Positioning System 

(GPS)/Location Data 

☐ Secure Digital (SD) Card or 

Other Data stored on a card or 

other technology 

☐ Device settings or preferences 

(e.g., security level, sharing 

options, ringtones).

☐ Network communications 

data 

☐ Cell tower records (e.g., logs. 

user location, time etc.)

☐ Other: 

Medical/Emergency Information Regarding Individuals

☐ Medical/Health Information ☐ Worker’s Compensation Act 

Information 

☐ Emergency Contact 

Information (e.g., a third party to 

contact in case of emergency

☐ Mental Health Information ☐ Information regarding a 

disability 

☐ Patient ID Number)

☐ Sick leave information ☐ Request for an 

accommodation under the 

Americans with Disabilities Act

☐ Patient ID Number 

☐ Other: 

Biometrics/Distinguishing Features/Characteristics of Individuals

☐ Physical description/ 

characteristics (e.g., hair, eye 

color, weight, height, sex, 

gender etc.) Identify which are 

collected: 

☐ Signatures ☐ Palm prints

☐ Fingerprints ☐ Photos/Video: ☐ Voice audio recording

☐ Other: 

Identifying numbers for sole proprietors (including business information).
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☐ Sole proprietor business 

credit card number

☒ Business Phone or Fax 

Number 

☒ Business Physical/Postal 

Mailing Address 

☐ Sole proprietor business 

professional license number

☐ Sole proprietor business file 

case number

☒ Sole proprietor business 

taxpayer identification number 

☐ Sole proprietor business 

license plate number

☐ Sole proprietor business 

vehicle identification number

☒ Sole proprietor business bank 

account number

☒ Other (Sole Proprietor 

business name). 

☐ Other (please describe): ☒ Other (please describe):

business bank Routing Tracking 

Number 

3.3 Sources from which PII is obtained

Focusing on the context in which the data was collected and used (i.e., why it is collected and how it is 

used), check ALL sources from which PII is collected/received and stored in the system or used in the 

project 

1. Members of the Public

☒ Members of the Public (i.e., including individuals who are current federal employees who are 

providing the information in their “personal” capacity (unrelated to federal work/employment)). 

All of the following are members of the public. Please check relevant boxes (based on the 

context of collection and use in this system) for members of the public whose information is 

maintained in the system (only check if relevant to the purpose for collecting and using the 

information):

☒ Members of the general public (current association with the federal government, if 

any, is irrelevant to the collection and use of the information by the system or project). 

☐ Retired federal employees. 

☐ Former Treasury employees. 

☐ Federal contractors, grantees, interns, detailees etc. (System administrators, system 

user logging) 

☐ Federal job applicants. 

☒ Other: Sole proprietors.

2. Current Federal Employees, Interns, and Detailees (payroll) 

☐ Current Federal employees providing information in their capacity as federal employees 

(for example, PII collected using OPM or Treasury forms related to employment with the 

federal government) 

☐ Interns. 

☐ Detailees. 

☐ Other employment-related positions. 

3. Treasury Bureaus (including Departmental Offices)

☐ Other Treasury Bureaus: 

4. Other Federal Agencies

☐ Other federal agencies: 

5. State and Local Agencies
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☐ State and local agencies: 

6. Private Sector

☒ Private sector organizations (for example, banks and financial organizations, data 

brokers or other commercial sources): Vendor or miscellaneous payments sent through 

Fiscal Service. Applicants are also private sector organizations.

7. Other Sources 

☐ Other sources not covered above (for example, foreign governments). 

 

Section 3.3: Privacy and/or civil liberties risks related to collection

When Federal agencies request information from an individual that will be maintained in a system of 

records, they must inform the individual of the following: “(A) the authority (whether granted by statute, 

or by executive order of the President) which authorizes the solicitation of the information and whether 

disclosure of such information is mandatory or voluntary; (B) the principal purpose or purposes for which 

the information is intended to be used; (C) the routine uses which may be made of the information, as 

published pursuant to paragraph (4)(D) of this subsection; and (D) the effects on [the individual], if any, 

of not providing all or any part of the requested information.” 5 U.S.C § 522a(e)(3). This is commonly 

called a Privacy Act Statement. The OMB Guidelines also note that subsection (e)(3) is applicable to 

both written and oral (i.e., interview) solicitations of personal information. Therefore, even if a federal 

employee or contractor has a fixed list of questions that they orally ask the individual in order to collect 

their information, this requirement applies. 

Section 3.3(a) Collection Directly from the Individual to whom the PII pertains

1. ☐ Treasury does not directly collect the PII in the system from the individuals to whom it 

pertains. The information is collected by states, U.S. territories, local governments, the 

Department of Hawaiian Home Lands, and Indian tribes or the tribally designated housing entity 

of an Indian tribe.

2. ☒ Some or ☐ all of the PII in this system of records was collected directly from the

individual/sole proprietor to whom it pertains. Sole proprietors apply to the CERTS program and 

provide the information being verified by the AVS. POCs are designated by each applicant 

seeking benefits. The POC is the person who completes the ID.me process to provide information 

to Treasury in support of the company’s application. If the applicant is a sole proprietor (and the 

sole proprietor is the POC), the POC information is collected directly from the individual. If the 

applicant is a company that is not a sole proprietor (or a sole proprietor who designates an 

employee to act as POC), the POC information is provided by a third party (the company/sole 

proprietor), not the individual POC. 

Section 3.3(b) Privacy Act Statements 

1. ☐ None of the PII in the system was collected by Treasury directly from the individuals to whom 

it pertains, but the information collected will not be stored in a system of records. Therefore, a 

Privacy Act Statement is not required. 

2. ☒ Some ☐ All of the PII in the system was collected directly from the individual to whom it 

pertains. Therefore, a Privacy Act Statement was posted at the point where the PII was collected

(or could be collected) directly from the individual. That Privacy Act Statement was provided to 

the individual ☒ on the application portal where the PII was collected ☐ on a separate sheet of 
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paper that the individual could retain; or ☐ in an audio recording or verbally at the point where 

the information was collected (e.g., on the phone) or ☐ other. 

3. The Privacy Act Statement contained the following: 

a. ☒ The authority (whether granted by statute, or by Executive order of the President) 

which authorizes the solicitation of the information.

b. ☒ Whether disclosure of such information is mandatory or voluntary. 

c. ☒ The principal purpose or purposes for which the information is intended to be used. 

d. ☒ The individuals or organizations outside of Treasury with whom the information 

may be/ will be shared.

e. ☒ The effects on the individual, if any, if they decide not to provide all or any part of 

the requested information.

Section 3.3(c) Use of Full Social Security Numbers 

Treasury is committed to eliminating unnecessary collection, use, and display of full Social Security 

numbers (“SSN”) and redacting, truncating, and anonymizing SSNs in systems and documents to limit 

their accessibility to individuals who do not have a need to access the full SSN in order to perform their 

official duties. Moreover, the Privacy Act provides that: “It shall be unlawful for any Federal, State or 

local government agency to deny to any individual any right, benefit, or privilege provided by law 

because of such individual’s refusal to disclose his social security account number.” Pub. L. No. 93–579, 

§ 7. This provision does not apply to: (1) any disclosure which is required by federal statute; or (2) any 

disclosure of an SSN to any federal, state, or local agency maintaining a system of records in existence 

and operating before January 1, 1975, if such disclosure was required under statute or regulation adopted 

prior to such date to verify the identity of an individual. Id. at § 7(a)(2)(A)-(B).

Section 3.3(d) Justification of Social Security Numbers

1. ☐ N/A No full SSNs are maintained in the system or by the project. [Explain if any portion of the 

SSN short of the full 9 digits is used in the system:; if the full SSN is located anywhere in the 

system (even if it is redacted, truncated or anonymized when viewed by users, please check 

number 2 below)].

2. ☒ Full SSNs are maintained in the system or by the project and the following approved Treasury 

uses of SSNs apply: 

☐ security background investigations; 

☐ interfaces with external entities that require the SSN; 

☐ a legal/statutory basis; 

☐ when there is no reasonable, alternative means for meeting business requirements; 

☒ statistical and other research purposes; 

☒ delivery of government benefits, privileges, and services; 

☐ for law enforcement and intelligence purposes; 

☐ aging systems with technological limitations combined with funding limitations render 

impracticable system modifications or replacements to add privacy risk reduction tools 

(partial/truncated/redacted or masked SSNs); and

☒ as a unique identifier for identity verification purposes. 
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Section 3.3(e) Controls implemented to limit access to and or improper disclosure of full Social 

Security Numbers

1. ☐ Full SSNs are not maintained in the system or by the project.

2. ☒ Full SSNs are maintained in the system or by the project and the following controls are put in 

place to reduce the risk that the SSN will be seen or used by someone who does not have a need 

to use the SSN in order to perform their official duties (check ALL that apply):

a. ☒ The entire SSN data field is capable of suppression (i.e., being turned off) 

and the data field is suppressed when the SSN is not required for particular 

system users to perform their official duties.

b. ☐ The SSN field is visible, but the SSN itself is blurred or distorted in some 

way so it is not capable of being read by users who do not require the SSN to 

perform their official duties.

c. ☐ Within the system, an alternative number (e.g., an Employee ID) is displayed 

to all system users who do not require the SSN to perform their official duties. 

The SSN is only linked to the alternative number within the system and when 

reporting outside the system (to an agency that requires the full SSN). The SSN 

is not visible to system users (other than administrators). 

d. ☐ The SSN is truncated (i.e., shortened to the last 4 digits of the SSN) when 

displayed to all system users for whom the last four digits (but not the full) SSN 

are necessary to perform their official duties.

e. ☐ Full or truncated SSNs are only downloaded to spreadsheets or other 

documents for sharing within the bureau or agency when disclosed to staff 

whose official duties require access to the full or truncated SSNs for the 

particular individuals to whom they pertain. No SSNs (full or truncated) are 

included in spreadsheets or documents unless required by each recipient to 

whom it is disclosed in order to perform their official duties (e.g., all recipients 

have a need to see the SSN for each employee in the spreadsheet). 

f. ☐ Other: [Please describe].

Section 3.3(f) Denial of rights, benefits, or privileges for refusing to disclose Social Security 

Number 

1. ☐ N/A No SSNs are maintained in the system or by the project. 

2. ☐ Full SSNs are collected, but no individual will be denied any right, benefit, or privilege 

provided by law if the individual refuses to disclose their SSN for use in the system or project. If 

the individual chooses not to provide their SSN [please describe here what will happen 

(something less than denial of a privilege etc.) if the individual chooses not to provide their 

SSN].

3. ☒ Full SSNs are collected, and individuals will be denied the following right, benefit, or 

privilege provided by law if they refuse to disclose their SSN. Denial of this right, benefit or 

privilege does not violate the law because: [choose one of the two boxes below]: 

a. ☒ SSN disclosure is required by the following Federal statute or Executive Order: the 

Consolidated Appropriations Act, 2021, Section 501(g). 

b. ☐ The SSN is disclosed to a Federal, state, or local agency that maintains a system of 

records that was in existence and operating before January 1, 1975, and disclosure was 

required under statute or regulation adopted prior to such date to verify the identity of 

an individual.
13

Section 3.3(g) Records describing how individuals exercise First Amendment rights 

The Privacy Act requires that Federal agencies “maintain no record describing how any individual 

exercises rights guaranteed by the First Amendment unless expressly authorized by statute or by the 

individual about whom the record is maintained or unless pertinent to and within the scope of an 

authorized law enforcement activity.” 5 U.S.C. § 552a(e)(7). 

1. ☒ N/A. The system or project does not maintain information describing how an individual 

exercises their rights guaranteed by the First Amendment. 

2. ☐ The system or project does maintain information describing how an individual exercises their 

rights guaranteed by the First Amendment. If you checked this box, please check the box below 

that explains Treasury’s authorization for collecting this information: 

a. ☐ The individual about whom the information was collected or maintained expressly 

authorizes its collection/maintenance. The individual about whom the information was 

collected or maintained expressly authorized its collection by (for example, individuals 

may expressly authorize collection by requesting in writing that Treasury share 

information with a third party, e.g., their Congressman];

b. ☐ The information maintained is pertinent to and within the scope of an authorized law 

enforcement activity because;

c. ☐ The following statute expressly authorizes its collection: [your response MUST 

contain all three if you use a statute as the basis for the collection].

Section 4: Maintenance, use, and sharing of the information

Section 4.1: Ensuring accuracy, completeness, and timeliness of information

collected, maintained, and shared when it is used to make determinations 

about individuals

The Privacy Act and Treasury policy require that Treasury bureaus and offices take additional care when 

collecting and maintaining information about individuals when it will be used to make determinations 

about those individuals (e.g., whether they will receive a federal benefit). This includes collecting 

information directly from the individual where practicable and ensuring that the information is accurate, 

relevant, timely and complete to assure fairness to the individual when making a determination about 

them. This section addresses the controls/protections put in place to address these issues. 

The Privacy Act requires that Federal agencies “maintain all records which are used by the agency in 

making any determination about any individual with such accuracy, relevance, timeliness, and 

completeness as is reasonably necessary to assure fairness to the individual in the determination.” 5 

U.S.C § 552a(e)(5). If a particular system of records meets certain requirements (including the NPRM

process defined in Section 3.1 above), an agency may exempt the system of records (or a portion of the 

records) from this requirement. Exemptions may be found at the bottom of the relevant SORN next to the 

heading: “Exemptions Claimed for this System.” 

Section 4.1(a). Exemption from the accuracy, relevance, timeliness, and completeness requirements 

in section (e)(5) of the Privacy Act 

1. ☒ None of the information maintained in the system or by the project (about sole proprietors

and POCs) that is part of a system of records is exempt from the accuracy, relevance, timeliness, 

and completeness requirements in section (e)(5) of the Privacy Act.
14

2. ☐ All ☐ Some of the PII maintained in the system or by the project is part of a system of records 

and is exempt from the accuracy, relevance, timeliness, and completeness requirements in 

section (e)(5) of the Privacy Act. The exemption claimed for these records is appropriate 

because [please see Appendix B which contains sample justifications for this exemption and 

provide the appropriate bases here [more than one bases may apply]. 

3. ☐ The PII maintained in the system or by the project is not part of a system of records as is 

required to trigger this requirement. 

Section 4.1(b) Protections in place despite the system of record’s exemption from the accuracy, 

relevance, timeliness, and completeness requirements or inapplicability of the Privacy 

Act.

1. ☒ None of the information maintained in the system or by the project (about sole proprietors)

that is part of a system of records is exempt from the accuracy, relevance, timeliness, and 

completeness requirements in section (e)(5) of the Privacy Act.

2. ☒ For all information maintained in the system or by the project that is part of a system of 

records that is exempt from the accuracy, relevance, timeliness, and completeness requirements 

in section (e)(5) of the Privacy Act, (or in the event the Privacy Act does not apply) the 

following efforts are made to ensure accuracy, relevance, timeliness, and completeness to the 

extent possible: 

a. ☐ The exempt information is not actually used to make any adverse determinations about 

individuals. 

b. ☐ The exempt information is not actually used to make any adverse determinations about 

individuals without additional research and investigation to ensure accuracy, relevance, 

timeliness, and completeness.

c. ☐ Individuals and organizations to whom PII from the system or project is disclosed (as 

authorized by the Privacy Act) determine its accuracy, relevance, timeliness, and 

completeness in a manner reasonable for their purposes before they use it to make adverse 

determinations about individuals.

d. ☒ Individuals/sole proprietors about whom adverse determinations are made using PII 

from this system or project are given an opportunity to explain or modify their 

information (check one) ☐ before ☒ after the adverse determination is made. During this 

process, individuals are allowed to: discuss with Treasury personnel the reason for the 

adverse determination. They are then given a reasonable amount of time to provide 

updated documentation or relevant information that shows that the adverse determination 

was made in error or should be reversed. 

3. ☐ Other: (please describe):

4. ☐ No additional efforts are made to ensure accuracy, relevance, timeliness, and completeness to 

the extent possible because it would interfere with mission requirements. 

Section 4.1(c) Collecting information directly from the individual when using it to make adverse 

determinations about them. 

Section 552a(e)(2) of the Privacy Act requires that Federal agencies that maintain records in a system of 

records are required to collect information to the greatest extent practicable directly from the individual 

when the information about them may result in adverse determinations about their rights, benefits, and 

privileges under Federal programs. Agencies may exempt a system of records from this requirement 

under certain circumstances and if certain conditions are met.

1. ☐ The records maintained by this system or project are not used to make any adverse 

determinations about individuals. 
15

2. ☒ The records maintained by this system or project (about sole proprietors) are used to make 

adverse determinations about individuals and [check all that apply]:

a. ☐ These records were exempted from the Privacy Act provision that requires collection 

directly from the subject individual to the greatest extent practicable. Exemption of these 

records is proper because. 

b. ☒ These records were not exempted from the requirement to collect information directly 

from the individual to the greatest extent practicable and [check the relevant box below and 

provide the information requested]. 

i. ☐ All records used to make an adverse determination are collected directly from the 

individual about whom the decision is made. 

ii. ☒ A combination of records collected from third parties and directly from the 

individual about whom the determination is made. This information includes the AVS 

payment file.

iii. ☐ None of the records used to make adverse determinations are collected directly from 

the individual about whom determinations are made because seeking the information 

directly from the individual might [select ALL that apply]: 

☐ alert the individual to the fact that their conduct is being observed or investigated; 

☐ cause the individual to alter or modify their activities to avoid detection;

☐ create risks to witnesses or other third parties if the individual is alerted to the 

fact that their conduct is being observed or investigated;

☐ Other: (please describe here).

Section 4.1(d) Additional controls designed to ensure accuracy, completeness, timeliness and 

fairness to individuals in making adverse determinations

1. Administrative Controls. Individuals about whom information is collected are given the 

following opportunities to amend/correct/update their information to ensure it is accurate, timely 

and complete to the extent reasonably necessary to assure fairness when it is used to make a 

determination about them: 

a. ☐ Treasury does not use the PII collected for use in the system or project to make adverse 

determinations about an individual’s rights, benefits, and privileges under federal programs. 

b. ☒ The records maintained in the system or by the project (about sole proprietors) are used to 

make adverse determinations and (select one) ☐ are ☒ are not exempt from the access 

provisions in the Privacy Act, 5 U.S.C. 552a(d). 

c. ☒ Treasury has published regulations in place describing how individuals may seek access 

to and amendment of their records under the Privacy Act. The Treasury/bureaus FOIA and 

Privacy Act disclosure regulations can be found at 31 C.F.R. Part 1, Subtitle A, Subparts A 

and C. 

d. ☐ Individuals who provide their information directly to Treasury for use in the system or by 

the project are provided notice of the adverse determination and an opportunity to 

amend/correct/ update their information [choose one] ☐ before ☐ after it is used to make a 

final, adverse determination about them. This is accomplished by [describe here how this 

process works and the protections in place, including redress/appeals processes; if notice is 

provided after an adverse determination is made, explain here why notice could not be 

provided before a determination was made, and the protections in place]:. 

e. ☒ Individuals who provide their information directly to Treasury for use in the system or by 

the project are expressly told at the point where the information is collected that they need to 
16

keep their information accurate, current and complete because it could be used to make 

adverse determinations about them. This is accomplished by this warning posted on the 

application portal: Anyone who knowingly submits a false claim or makes a false statement 

is subject to criminal and/or civil penalties, including confinement for up to 5 years, fines, 

and civil penalties (18 U.S.C. §§ 287, 1001; 31 U.S.C. §§ 3729, 3802). Treasury may refer 

any allegations of fraud, waste, or abuse in connection with CERTS to the Treasury 

Inspector General. 

f. ☐ All manual PII data entry by federal employees/contractors is verified by a supervisor or 

other data entry personnel before it is uploaded to the system (e.g., PII entered into the 

system from paper records is double-checked by someone else before it’s uploaded to the 

system). This is accomplished by: 

g. ☐ Other: 

2. Technical controls. The system or project also includes additional technical controls to ensure 

that PII is maintained with such accuracy, relevance, timeliness and completeness as is 

reasonably necessary to assure fairness to the individual when it is used to make a determination 

about them. The following additional protections are relevant to this system or project 

a. ☐ No additional technical controls are available to ensure accuracy, relevance, timeliness 

and completeness. 

b. ☐ Automated data feeds are used to refresh/update the information in the system (where the 

system is reliant on updates from another system). These automated data feeds occur:. 

c. ☐ Technical and/or administrative controls put are in place to ensure that when information 

about an individual is acquired from multiple sources for maintenance in a single file about a 

particular individual, it all relates to the same individual . This is accomplished by:.

d. ☐ Address verification and correction software (software that validates, updates and 

standardizes the postal addresses in a database).

e. ☒ Other: Technical controls and data validation are documented in the CERTS Review 

Guide. This includes restricted access of Treasury personnel and staff to the records 

requiring written justification for both “read-only” and “editing” permissions. 

Section 4.2 Data-Mining

As required by Section 804 of the Implementing Recommendation of the 9/11 Commission Act of 2007

(“9-11 Commission Act”), Treasury reports annually to Congress on its data mining activities. For a 

comprehensive overview of Treasury’s data mining activities, please review the Department’s Annual 

Privacy Act and Data Mining reports available at: http://www.treasury.gov/privacy/annual-reports. 

Section 4.2(a) Is the PII maintained in the system used to conduct data-mining?

1. ☒ The information maintained in this system or by this project (about sole proprietors) is not

used to conduct “data-mining” activities as that term is defined in the 9-11 Commission Act. 

Therefore, no privacy or civil liberties issues were identified in responding to this question.

2. ☐ The information maintained in this system or by this project is used to conduct “data-mining” 

activities as that term is defined in the 9-11 Commission Act. This system is included in 

Treasury’s annual report to Congress which can be found on the external Treasury privacy 

website.

3. ☐ The information maintained in this system or by this project is used to conduct “data-mining” 

activities as that term is defined in the 9-11 Commission Act, but this system is not included in 

Treasury’s annual report to Congress which can be found on the external Treasury privacy 

website. This system will be added to the next Treasury Data-mining report to Congress. 

Section 4.3 Computer Matching
17

The Computer Matching and Privacy Protection Act (CMPPA) of 1988 amended the Privacy Act

by imposing additional requirements when Privacy Act systems of records are used in computer 

matching programs. Pursuant to the CMPPA, there are two distinct types of matching programs. 

The first type of matching program involves the computerized comparison of two or more 

automated federal personnel or payroll systems of records or a system of federal personnel or 

payroll records with non-federal records. This type of matching program may be conducted for 

any purpose. The second type of matching program involves the computerized comparison of 

two or more automated systems of records or a system of records with non-federal records. The 

purpose of this type of matching program must be for the purpose of eligibility determinations or 

compliance requirements for applicants, recipients, beneficiaries, participants, or providers of 

services for payments or in-kind assistance under federal benefit programs, or recouping 

payments or delinquent debts under such federal benefit programs. See 5 U.S.C. § 522a(a)(8). 

Matching programs must be conducted pursuant to a matching agreement between the source (the 

agency providing the records) and recipient agency (the agency that receives and uses the records 

to make determinations). The matching agreement describes the purpose and procedures of the 

matching and establishes protections for matching records.

Section 4.3(a) Records in the system used in a computer matching program

1. ☐ The PII maintained in the system or by the project is not part of a Privacy Act system of 

records. 

2. ☒ Some of the information maintained in the system or by the project (about sole proprietors

and POCs) is part of a Privacy Act system of records, but none of the information is used as part 

of a matching program. 

3. ☐ The information maintained in the system or by the project is part of a Privacy Act system of 

records and is used as part of a matching program. [If whether a Matching Agreement was 

executed and published as required by the CMPPA/Privacy Act; if no Matching Agreement was 

executed, please explain here why].

Section 4.3(b) Is there a matching agreement?

1. ☒ N/A

2. ☐ There is a matching agreement in place that contains the information required by Section (o) 

of the Privacy Act. 

3. ☐ There is a matching agreement in place, but it does not contain all of the information required 

by Section (o) of the Privacy Act. The following actions are underway to amend the agreement 

to ensure that it is compliant. [discuss here the issues that were discovered that required 

amendment and how those issues are being mitigated/fixed]:. 

Section 4.3(c) What procedures are followed before adverse action is taken against an individual 

who is the subject of a matching agreement search?

1. ☒ N/A

2. ☐ The bureau or office that owns the system or project conducted an assessment regarding the 

accuracy of the records that are used in the matching program and the following additional 

protections were put in place:

a. ☐ The results of that assessment were independently verified by [explain how and by whom 

accuracy is independently verified; include the general activities involved in the verification 

process].
18

b. ☐ Before any information subject to the matching agreement is used to suspend, terminate, 

reduce, or make a final denial of any financial assistance or payment under a Federal benefit 

program to an individual: 

i. ☐ The individual receives notice and an opportunity to contest the findings; OR 

ii. ☐ The Data Integrity Board approves the proposed action with respect to the financial 

assistance or payment in accordance with Section (p) of the Privacy Act before taking 

adverse action against the individual. 

3. ☐ No assessment was made regarding the accuracy of the records that are used in the matching 

program. 

Section 4.4: Information sharing with external (i.e., outside Treasury) 

organizations and individuals

Section 4.4(a) PII shared with/disclosed to agencies, organizations or individuals outside Treasury

1. ☐ PII maintained in the system or by the project is not shared with agencies, organizations, or 

individuals external to Treasury. 

2. ☐ PII maintained in the system or by the project is or may be shared with the following agencies, 

organizations, or individuals external to Treasury. 

3. ☒ All external disclosures are authorized by the Privacy Act (including routine uses in the 

applicable SORN(s)). 

Section 4.4(b) Accounting of Disclosures

An accounting of disclosures is a log of all external (outside Treasury) disclosures of records made from a 

system of records that has not been exempted from this accounting requirement. This log must either be 

maintained regularly or be capable of assembly in a reasonable amount of time after an individual makes a 

request. Certain system of records may be exempted from releasing an accounting of disclosures (e.g., in 

law enforcement investigations). 

Section 4.4(c) Making the Accounting of Disclosures Available 

1. ☐ The records are not maintained in a system of records subject to the Privacy Act so an 

accounting is not required. 

2. ☐ No external disclosures are made from the system. 

3. ☐ The Privacy Act system of records maintained in the system or by the project is

exempt from the requirement to make the accounting available to the individual named 

in the record. Exemption from this requirement was claimed because:

4. ☐ The Privacy Act system of records maintained in the system or by the project is not

exempt from the requirement to make the accounting available to the individual named 

in the record and a log is maintained regularly. The log is maintained for at least five 

years and includes the date, nature, and purpose of each disclosure (not including intraagency disclosures and FOIA disclosures) of a record to any person or to another 

agency (outside of Treasury) and the name and address of the person or agency to 

whom the disclosure is made. 

5. ☒ The Privacy Act system of records maintained in the system or by the project is not

exempt from the requirement to make the accounting available to the individual named 

in the record and a log is not maintained regularly, but is capable of being constructed 

in a reasonable amount of time upon request. The information necessary to reconstruct 

the log (i.e., date, nature, and purpose of each disclosure) is maintained for at least five 

years.
19

Section 4.4(d) Obtaining Consent Prior to New Disclosures Not Authorized by the Privacy Act

Records in a system of records subject to the Privacy Act may not be disclosed by "any means 

of communication to any person or to another agency" without the prior written request or 

consent of the individuals to whom the records pertain. 5 U.S.C. Sec. 552a(b). However, the 

Act also sets forth twelve exceptions to this general restriction. These 12 exceptions may be 

viewed at: https://www.justice.gov/usam/eousa-resource-manual-139-routine-uses-andexemptions. Unless one of these 12 exceptions applies, the individual to whom a record 

pertains must provide their consent, where feasible and appropriate, before their records may be 

disclosed to anyone who is not listed in one of the 12 exceptions. One of these 12 exceptions 

also allows agencies to include in a notice published in the Federal Register, a list of routine 

uses. Routines uses are disclosures outside the agency that are compatible with the purpose for 

which the records were collected. 

Section 4.4(e) Obtaining Prior Written Consent

1. ☒ The records maintained in the system of records are only shared in a manner 

consistent with one of the 12 exceptions in the Privacy Act, including the routine uses 

published in the Federal Register. 

2. ☒ If a situation arises where disclosure (written, oral, electronic, or mechanical) must 

be made to anyone outside of Treasury who is not listed in one of the 12 exceptions in 

the Privacy Act, the individual’s prior written consent will be obtained where feasible 

and appropriate. 

3. ☐ The Privacy Act does not apply. 

Section 5: Compliance with federal information management requirements

Responses to the questions below address the practical, policy, and legal consequences of 

failing to comply with one or more of the following federal information management 

requirements (to the extent required) and how those risks were or are being mitigated: (1) the 

Privacy Act System of Records Notice Requirement; (2) the Paperwork Reduction Act; (3) the 

Federal Records Act; (4) the E-Gov Act security requirements; and (5) Section 508 of the 

Rehabilitation Act of 1973. 

Section 5.1: The Paperwork Reduction Act

The PRA requires OMB approval before a Federal agency may collect standardized data from 10 or more 

respondents within a 12-month period. OMB also requires agencies to conduct a PIA (a Treasury 

PCLIA) when initiating, consistent with the PRA, a new electronic collection of PII for 10 or more 

persons (excluding agencies, instrumentalities, or employees of the federal government).

Section 5.1(a)

1. ☒ The system or project maintains information obtained from individuals and organizations who 

are not federal personnel or an agency of the federal government (i.e., outside the federal 

government). 

2. ☒The project or system involves a new collection of information in identifiable form for 10 or 

more persons from outside the federal government. 

3. ☒ The project or system completed an Information Collection Request (“ICR”) and received 

OMB approval. OMB approval number: 1505-0273.

4. ☐ The project or system did not complete an Information Collection Request (“ICR”) and 

receive OMB approval.
20

Section 5.2: Records Management - NARA/Federal Records Act 

Requirements

Records retention schedules determine the maximum amount of time necessary to retain information in 

order to meet the needs of the project or system. Information is generally either disposed of or sent to the 

National Archives and Records Administration (NARA) for permanent retention upon expiration of this 

period. If the system has an applicable SORN(s), check the “Policies and Practices for Retention and 

Disposal of Records” section.

Section 5.2(a) 

1. ☒ The records used in the system or by the project are covered by a NARA’s General

Records Schedule (GRS). The GRS is 1.2: Grant and Cooperative Agreement 

Records.

2. ☐ The records used in the system or by the project are covered by a NARA approved 

Treasury bureau Specific Records Schedule (SRS). The SRS 

3. ☐ On [please state the date on which NARA approval was sought] the system owner 

sought approval from NARA for an SRS and is awaiting a response from NARA..

4. ☐ The system owner is still in the process of developing a new records schedule to 

submit to NARA.

Section 5.3: E-Government Act/NIST Compliance 

The completion of Federal Information Security Management Act (FISMA) Security 

Assessment & Authorization (SA&A) process is required before a federal information 

system may receive Authority to Operate (ATO). 

Section 5.3(a) 

1. ☒ The system is a federal information system subject to FISMA requirements.

2. ☒ The system last completed an SA&A and received an ATO on: May 23, 2021. 

3. ☐This is a new system has not yet been authorized to operate. The expected to date for receiving 

ATO is. 

4. ☒The system or project maintains access controls to ensure that access to PII maintained is 

limited to individuals who have a need to know the information in order to perform their official 

Treasury duties.

5. ☐ All Treasury/bureau security requirements are met when disclosing and transferring 

information (e.g., bulk transfer, direct access by recipient, portable disk, paper) from the Treasury 

system or project to internal or external parties.

6. ☐ This system or project maintains an audit log of system users to ensure they do not violate the 

system and/or Treasury/bureau rules of behavior. 

7. ☐ This system or project has the capability to identify, locate, and monitor individuals or groups 

of people other than the monitoring of system users to ensure that they do not violate the system’s 

rules of behavior. 

Section 5.4: Section 508 of the Rehabilitation Act of 1973

When Federal agencies develop, procure, maintain, or use Electronic and Information Technology (EIT), 

Section 508 of the Rehabilitation Act of 1973 (as amended in 1998) requires that individuals with 

disabilities (including federal employees) must have access and use (including privacy policies and 

directives as well as redress opportunities) that is comparable to that which is available to individuals who 

do not have disabilities.
21

Section 5.4(a) 

1. ☐ The project or system will not involve the development, procurement, maintenance or use of 

EIT as that term is defined in Section 508 of the Rehabilitation Act of 1973 (as amended in 

1998)? 

2. ☒ The project or system will involve the development, procurement, maintenance or use of EIT 

as that term is defined in Section 508 of the Rehabilitation Act of 1973 (as amended in 1998)? If 

checked:

3. ☒ The system or project complies with all Section 508 requirements, thus ensuring that 

individuals with disabilities (including federal employees) have access and use (including access 

to privacy and civil liberties policies) that is comparable to that which is available to individuals 

who do not have disabilities. 

4. ☐ The system or project is not in compliance with all Section 508 requirements. The following 

actions are in progress to ensure compliance:. 

Responsible Officials

Approval Signature

________________________________ 

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer

Departmental Offices, & Records