Federal Trade Commission 

Privacy Impact Assessment 

Zoom for Government 

(ZoomGov) 

March 2021 

Reviewed May 2023 
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Table of Contents 

System Overview.................................................................................................................... 1 

Data Type, Sources, and Use .................................................................................................. 1 

Data Access and Sharing ........................................................................................................ 4 

Notice and Consent................................................................................................................. 7 

Data Accuracy and Security.................................................................................................... 9 

Data Retention and Disposal................................................................................................. 10 

Website Privacy Evaluation.................................................................................................. 10 

Privacy Risks and Evaluation ............................................................................................... 10 
 

 

 

1 System Overview 

1.1 Describe the project/system and its purpose. 

Zoom for Government (ZoomGov) is a web-based tool that allows video, voice, content 

sharing, and chat service and is used by the Federal Trade Commission (FTC) to collaborate 

in a virtual environment. The FTC’s implementation of ZoomGov as a Software as a Service 

(SaaS) platform allows users to meet online, with or without video, and unifies cloud video 

conferencing, online meetings and a software-defined conference room solution into one 

platform. The solution offers video, audio, and wireless screen-sharing across various types 

of electronic devices and Operating Systems (OS). 

ZoomGov is used by the FTC to conduct virtual meetings both internally within the agency 

and externally with non-FTC entities. This includes members of the public, such as 

individuals that staff or represent other government agencies (local, state, and federal), 

members of Congress and/or their staff, external law enforcement partners and associations, 

industry representatives, consumer advocacy groups, etc. 

1.2 What specific legal authority allows for the collection, maintenance, or 

dissemination of information for this project/system? 

The information in this system is collected, maintained and disseminated pursuant to the 

Federal Trade Commission Act, 15 U.S.C. §§ 41-58. Information collected, generated, or 

maintained by the system for administrative and security purposes is authorized under the 

Federal Information Security Modernization Act (FISMA), Pub. L. No. 113-283, 44 U.S.C. 

3551 et seq. 

2 Data Type, Sources, and Use 

2.1 Specify in the table below what types of personally identifiable information (PII)1 

may be collected or maintained in the system/project. Check all that apply. 

In order to use ZoomGov, participants are required to provide an email address and user 

name; the user name could be the individual’s real name or an alias. Additional information 

may also be collected depending on the nature of the session; this may include the person’s 

company/organization name, phone number, photo, and/or real-time video (with user’s 

permission). Information provided by participants to any meeting hosted by the FTC are 

used by the agency to allow participation in ZoomGov sessions; the FTC may also use some 

aggregate information for statistical purposes when assessing account usage and scope. 

Additionally, ZoomGov uses information about the types of devices and systems used by 

participants (e.g., computer type, speaker, microphone, operating system, average bandwidth) 

1 Per OMB Circular A-130, personally identifiable information (PII) means information that can be used to 

distinguish or trace an individual’s identity, either alone or when combined with other information that is linked or 

linkable to a specific individual. 

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to facilitate a seamless participant meeting experience and help ensure the participant’s 

desired configurations are utilized in the meeting experience. 

PII Elements: This is not intended to be an exhaustive list. Specify other categories of PII as 

needed. 

Full Name Biometric Identifiers (e.g., User ID (First/Last Name) 

Date of Birth fingerprint, voiceprint) Internet Cookie Containing 

Home Address Audio Recordings PII 

Phone Number(s) Photographic Identifiers (e.g., Employment Status, History, 

Place of Birth image, x-ray, video) or Information 

Age Certificates (e.g., birth, death, Employee Identification 

Race/ethnicity marriage, etc.) Number (EIN) 

Alias Legal Documents, Records, Salary 

Sex Notes (e.g., divorce decree, Military Status/Records/ ID 

Email Address criminal records, etc.) Number 

Work Address Vehicle Identifiers (e.g., IP/MAC Address 

Taxpayer ID license plates) Investigation Report or 

Credit Card Number Financial Information (e.g., Database 

Facsimile Number account number, PINs, Driver’s License/State ID 

Medical Information passwords, credit report, etc.) Number (or foreign country 

Education Records Geolocation Information equivalent) 

Social Security Number Passport Number Other (Please Specify): 

Mother’s Maiden Name Open chat field where 

participants can enter any 

kind of information; 

recorded content; 

documents/files shared that 

may contain PII; language 

preference 

2.2 What types of information other than PII will be collected, disseminated, or 

maintained by the project/system? Provide a general description below and be sure 

to include all data elements. 

The FTC has configured ZoomGov to allow users to share various files for presentations and 

dissemination to other meeting participants. These files can be downloaded locally by 

meeting participants and/or featured in any recording. Such files can contain any and all 

types of information that may be nonpublic and sensitive in nature. 

In addition to the PII elements identified in section 2.1 above, ZoomGov logs various non-PII 

elements (some of which may be connected to individuals’ names or accounts) relating to 

events and usage for the meeting (e.g, total meeting time, date, start time, end time, topic, 

meeting ID, session ID, other metrics about when and how meetings were conducted, and 

what features were used), the device, end point and system environment attributes 

participating in the meeting (e.g. UUID, IP address, MAC address, operating system, user 

agent, average bandwidth), performance data (e.g., relating to how the services perform), 

service logs (e.g., relating to information on system events and states), and other operational 

or metadata. 

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2.3 What is the purpose for collection of the information listed above? 

ZoomGov collects and stores participants’ email addresses and names (including phone 

numbers and profile photo if provided). Email addresses, names, User IDs/aliases, as well as 

video images of users and profile pictures are used by Zoom to facilitate event access, 

authentication, performance, and event management. Email addresses can be used by the 

FTC to transmit ZoomGov invitations to recipients. When individuals are invited to a 

ZoomGov session via an email, they receive an emailed invitation from the event/meeting 

organizer with the details of the meeting, including the date, time, and any other relevant 

data. The link to join that particular session is embedded within the email invitation. A 

unique password is also included in the email invitation. The participant accesses the 

ZoomGov session by clicking on the embedded link in the email. Zoom stores the phone 

number of the billing point of contact and any phone numbers entered voluntarily into the 

profile information by a user as an optional field. This information is stored to enable that 

user to display their phone number to their contacts. A phone number will also be collected 

if Zoom Phone is used. 

Provided that they have received prior authorization from an FTC account administrator, 

FTC meeting hosts or co-hosts may have the ability to record portions or entire ZoomGov 

sessions. This includes video, audio, as well as any public chat content generated during that 

particular session. Individuals will be notified if a meeting is being recorded and have the 

opportunity to leave the meeting or to mute audio and/or video to avoid having their voice 

and/or likeness recorded. The FTC can enable meeting hosts to record content for reference. 

Content can be stored both locally and in the ZoomGov cloud. The FTC has configured 

ZoomGov to allow users to share various files for presentations and dissemination to other 

meeting participants. These files can be downloaded locally by meeting participants and/or 

featured in any recordings for reference. 

In addition to the PII elements identified above, ZoomGov logs various non-PII elements, as 

discussed above, for troubleshooting, security, operation and improvement of ZoomGov 

products and services, and performance improvement. 

2.4 What are the sources of the information in the system/project? How is the 

information collected? 

Source of Data Type of Data Provided & How It Is Collected 

FTC staff/contractors 

(internal users) 

FTC users must provide their email address in order to 

receive meeting invitations sent via ZoomGov. Names, 

photos and/or aliases are also collected when users log on to 

participate in a ZoomGov session. Depending on their 

participation, FTC users also contribute video and audio, text 

or file content to the ZoomGov session. 

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Source of Data Type of Data Provided & How It Is Collected 

Members of the public Non-FTC users are also required to provide an email address 

(external users) in order to receive a ZoomGov meeting invitation. When 

logging onto the ZoomGov session, individuals can opt to use 

their real names or choose usernames/aliases. The following 

information may also be collected by the FTC depending on 

the nature of the session: organization/company name; phone 

number; individual’s photo and/or real-time video; real-time 

audio; chat messages and/or files. 

Participants’ Devices ZoomGov collects information through metadata and 

(of internal and operational information about the types of devices and 

external users) systems used by participants (e.g., computer type, speaker, 

microphone, operating system, average bandwidth) to 

facilitate a seamless participant meeting experience and help 

ensure the participant’s desired configurations are utilized in 

the meeting experience. 

Zoom Meeting ZoomGov generates and/or collects information relating to 

Sessions events and usage for meetings (e.g, total meeting time, date, 

start time, end time, topic, participants, meeting ID, session 

ID, other metrics about when and how meetings were 

conducted, and what features were used), performance data 

(e.g., relating to how the services perform), service logs (e.g., 

relating to information on system events and states), and other 

operational information or metadata related to meeting 

sessions. 

3 Data Access and Sharing 

3.1 In the table below, specify the systems/applications and groups (both FTC and nonFTC) that will have access to or share data in the system/project. 

Data Will Be Accessed 

By and/or Provided To: How and Why the Data Will Be Accessed/Shared 

FTC staff/contractors 

(internal users) 

Internal participants in ZoomGov meetings hosted by the 

FTC will be able to access or view the email addresses, 

participant names and photos of meeting participants (if 

provided), and the meeting name, description and login 

details for the session. 

In addition, internal participants will be able to see and hear 

real-time video and audio feeds for all participants in the 

session (if not muted or disabled by those participants), any 

photos participants have added to their Zoom background, 

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Data Will Be Accessed 

By and/or Provided To: How and Why the Data Will Be Accessed/Shared 

and the contents of any chats or files shared with all 

participants during the meeting. 

The categories of information about live and past meetings 

and webinars hosted on the ZoomGov account that FTC 

designated administrators can access include: 

- Meeting information, including meeting ID, meeting 

topic, host name, start time, number of participants, 

whether participants join by phone, whether 

participants join audio via computer or mobile device, 

whether participants join with video, whether there 

was screen sharing during the meeting, whether the 

meeting is or was being recorded, whether an 

H.323/SIP device joined the meeting, whether the 

meeting is or was encrypted. 

- Meeting and participant profile information, including 

participant names; device participant was connecting 

from; IP addresses; location; network type (wired, 

wifi, 4G, etc.); network health (whether any warning 

level or critical level issues in meeting); issues 

(connection/client health warnings, e.g., unstable 

audio or video); selected microphone, speaker, and 

camera devices; which data center the participant 

connected to for the meeting; connection type (the 

data protocol type the participant is or was using); and 

join and leave times. 

- Detailed stats for Audio, Video, and Screen Sharing, 

including the bitrate, latency, jitter, as well as packet 

loss average and maximum. For Video and Screen 

Sharing, you can also view the resolution and 

framerate. 

- CPU Usage including the minimum, average, and 

maximum used by Zoom during the meeting/webinar, 

as well as the maximum used by a participant’s 

system (device) overall during the meeting. 

FTC Hosts and Administrators: in order to invite participants 

to hosted meeting using the individual’s name/email listed in 

the system, the FTC Host must be a member of a built in 

group to create/invite meetings. FTC Administrators create, 

manage, and monitor internal FTC user accounts. 

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Data Will Be Accessed 

By and/or Provided To: How and Why the Data Will Be Accessed/Shared 

Members of the public Non-FTC individuals who use ZoomGov to participate in 

(external users) virtual meetings with the FTC will have access to the email 

addresses, participant names and photos (if provided) of other 

participants to the meeting, as well as the meeting name, 

description and login details for the session. 

In addition, external participants will be able to see and hear 

real-time video and audio feeds for all participants in the 

session (if not muted or disabled by those participants), any 

photos participants have added to their Zoom background, 

and the contents of any chats or files shared during the 

meeting. 

ZoomGov and Zoom Zoom engineers: Designated Zoom engineers can access data 

Cloud Service associated with FTC’s ZoomGov account and sessions hosted 

Providers (CSPs) on that account to provide the ZoomGov service to the FTC, 

including performance, authentication and event management 

and improvement. Zoom has access to participants’ 

names/aliases, email address, what type of device the 

participant is using, and IP address. 

Amazon Web Services (AWS): As a CSP, AWS provides the 

hosted environment for ZoomGov and has access to FTC 

information that is encrypted at disk level for maintenance 

and technical support purposes. 

3.2 Do contractors and/or third party service providers have access to data in the 

project/system? If yes, explain what privacy requirements are in place to ensure 

that data is properly protected. 

Yes, authorized FTC contractors have access to FTC data in ZoomGov. FTC contractors are 

subject to the same rules and guidelines as FTC federal employees and must adhere to 

established FTC policies and procedures. FTC contractors are required to complete the 

mandatory Privacy and Security Awareness training upon hire and at least annually 

thereafter. FTC's use of Zoom for Government leverages the built-in groups for managing 

the different levels of access allowed upon the system. The FTC defined User Groups within 

the Zoom for Government system are the following: Administrators and Standard Users. 

These groups are required to obtain access authorization from the FTC Zoom system 

stewards before being granted access. Roles within the Zoom for Government application are 

assigned based upon Role Based Access Controls (RBAC) and the least privilege model. The 

assignments correspond to the performance of their required duties which are defined to be 

either Users or Administrators. 

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ZoomGov and Zoom Cloud Service Providers also may have system data access. See section

3.1 above. The ZoomGov cloud is hosted by AWS in a dedicated cloud that is maintained 

separate from Zoom’s commercial cloud. Zoom staff are subject to mandatory security 

awareness and privacy training for all users; role-based training for privileged users; 

personnel screening as required by FTC; and completion of contractual agreements and Rules

of Behavior in accordance with applicable FTC policies. AWS also uses various security and

privacy features to ensure protection, including as described by materials made available by 

AWS. 

3.3 If you answered “yes” to 3.2, describe the privacy incident response plan maintained 

by the contractor’s organization or third party service provider. 

FTC contractors are subject to the same FTC privacy incident response plan as its federal 

staff. Zoom maintains its own incident response plan and requires all employees to complete 

annual privacy and security awareness training. 

4 Notice and Consent 

4.1 How are individuals provided with notice prior to the collection of their PII? If 

notice is not provided, explain why. 

 Notice is provided via (check all that apply): 

Privacy Act Statement ( Written Oral) 

FTC Website Privacy Policy 

Privacy Notice (e.g., on Social Media platforms)

 Login banner 

Other (explain): Prior to joining a live session, participants are provided with a notice 

that information may be collected for US Government-authorized use. Communication 

or data transiting or stored by the FTC or on behalf of the FTC may be disclosed or used 

for lawful Government purposes as necessary. 

Notice is not provided (explain): _________________________________________________ 

4.2 Do individuals have the opportunity to decline to provide information or to consent 

to particular uses of their information (other than required or authorized uses)? 

Yes. Individuals are required to provide their email address in order to receive the ZoomGov 

invitation. If they choose to not provide this information, they will be ineligible to 

participate in the session via ZoomGov. In addition, individuals can decline a meeting 

invitation and choose not to join a session hosted on ZoomGov or can disable video or audio 

during the session to prevent transmission of their voice or image; they may also choose to 

use an alias versus a real name during the meeting. Individuals will be notified if a meeting 

is being recorded and have the opportunity to leave the meeting or to mute audio and/or 

video to avoid having their voice and/or likeness recorded. Users may voluntarily participate 

in chat communications, with the understanding that such communications (unless directed 

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4.3 Are there procedures in place to allow individuals access to their personally 

identifiable information? Explain. 

 

privately to another user) may be available for viewing by other users and may be 

logged/transcribed by other users and/or the system. 

Yes. When participating in a ZoomGov session, individual users have access to and can 

modify their user name, alias, contact information, and organization name. They also have 

the option to disable their camera and microphone features if they do not wish to make their 

picture or voice available to the rest of the participants. 

Individuals may request access to federal agency records or information through Freedom of 

Information Act (FOIA) requests (with the exception of certain types of records). The 

Privacy Act allows most individuals to seek access to federal agency records about 

themselves and affords that person the right to challenge the accuracy of the information 

contained about them. An individual may make a request under the Privacy Act for access to 

information maintained and retrieved according to personal identifier by the FTC about 

themselves in the FTC’s Privacy Act systems. The FTC’s Privacy Policy provides links to 

the FTC’s System of Records Notices (SORNs), as well as information about making 

Freedom of Information Act (FOIA) requests and the online FOIA request form. Individuals 

seeking access must follow the FTC’s Privacy Act rules and procedures, published in the 

Code of Federal Regulations (C.F.R.) at 16 C.F.R. 4.13. 

4.4 Are there procedures in place to allow individuals the ability to correct inaccurate 

or erroneous information? What is the process for receiving and responding to 

complaints, concerns, or questions from individuals? Explain. 

Yes, see Section 4.3. In addition, to the extent the Privacy Act applies, the FTC provides a 

process for individuals to correct or amend any inaccurate PII maintained by the FTC in 

agency records retrieved by the name of the individual or other personally assigned identifier. 

See section 8.4 below. The FTC’s Privacy Policy provides links to the FTC’s SORNs, which 

include information about how to correct or amend records. An individual may make a 

request under the Privacy Act for access to information maintained by the FTC about 

themselves in Privacy Act systems. Access to the information under the Privacy Act is 

subject to certain exemptions. Individuals may also file FOIA requests for agency records 

about them (if they are not exempt from disclosure to them under those laws). Additionally, 

individuals may contact the FTC with any complaints, questions or concerns via phone or 

email available on www.ftc.gov or contact the Chief Privacy Officer directly. 

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5 Data Accuracy and Security 

5.1 Are there procedures in place to ensure that the information maintained is accurate, 

complete, and up-to-date? 

On a quarterly basis, FTC ZoomGov System Administrators review the FTC configuration of 

ZoomGov to ensure the following: review account access; enabling, modifying, disabling 

and removing account access; and ensuring that only identified and registered FTC assigned 

personnel have access to the FTC Zoom instance. 

5.2 Are there administrative procedures and technical safeguards in place to protect the 

data in the system/project? What controls are in place to ensure proper use of the 

data? Please specify. 

PII is secured within the system maintained by the FTC through the use of administrative 

controls in the form of mandatory security awareness and privacy training for all users; rolebased training for privileged users; personnel screening as required by the FTC; and 

completion of contractual agreements and Rules of Behavior, in accordance with applicable 

FTC policies. These controls include, but are not limited to, minimizing privileged users, 

prohibiting account sharing, and conducting monthly user audits. 

Zoom utilizes administrative controls in the form of role-based access restrictions; mandatory 

security awareness and privacy training for all Zoom employees; personnel screening, 

including role-specific screening criteria; completion of contractual agreements and a Code 

of Business Conduct and Ethics; a formal sanctions process for those Zoom personnel who 

fail to comply with Zoom policies and procedures; a vendor selection committee process; and 

a Vendor Security Management Policy. 

Physical controls include hosting applicable data within data centers (AWS) which control 

and monitor physical access to the system components, including visitor control and auditing 

of access records; and, protection of power equipment and cabling, transmission medium, 

output devices and use of emergency power and shutoff systems as well as fire and water 

damage protection. 

Zoom employs Network Access Controls (NAC) and network monitoring to prevent 

unauthorized devices from physically connecting to the data centers/co-locations. Zoom 

employs next-generation firewall on both the production and corporate network, which 

includes advanced threat protection, which provides: 

- Full visibility into all network traffic, including stealthy attempts to evade detection, 

such as the use of non-standard ports or SSL encryption. 

- Attack surface reduction with positive security controls to proactively take away 

infection vectors. 

- Automatic known threat prevention firewall, threat prevention, URL filtering, 

advanced endpoint protection and a security service, providing defenses against 

known exploits, malware, malicious URLs and command-and-control (C2) activity. 

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- Zero-day threat detection and prevention, including threat analytics with high 

relevance and context. 

Zoom’s administrative and technical controls are evaluated as part of the annual FedRAMP 

certification. 

5.3 Is PII used in the course of system testing, training, or research? If so, what steps 

are taken to minimize and protect PII during this process? 

 Not Applicable. 

6 Data Retention and Disposal 

6.1 Specify the period of time that data is retained in the system/project. What are the 

specific procedures for disposing of the data at the end of the retention period? 

GRS 3.1 covers General Technology Management records and GRS 3.2 for System Security 

Management records. The FTC will retain the recorded content and chats until such time that 

a NARA-approved records disposition schedule can be implemented. 

7 Website Privacy Evaluation 

7.1 Does the project/system employ the use of a website? If so, describe any tracking 

technology used by the website and whether the technology is persistent or 

temporary (e.g., session cookie, persistent cookie, web beacon). Describe the 

purpose of using such tracking technology. 

Zoom employs cookies to recognize a device or user for purposes of performance, 

troubleshooting, authentication, anti-fraud and security. For additional information, see 

Zoom’s Cookie policy. 

8 Privacy Risks and Evaluation 

8.1 Considering the type of information collected and sources of collection, what 

privacy risks were identified and how were these risks mitigated? 

Risk Mitigation Strategy 

Individuals who have 

access to PII could 

exceed their authority 

and use the data for 

unofficial/unauthorized 

purposes. 

System administrators strictly manage access control and 

limit the use and access of all data to purposes for which it 

was collected. A system log is maintained that reflects who 

accessed the data at any given time, and whether the data was 

tampered with or edited. 

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Risk Mitigation Strategy 

Unauthorized 

participants in 

ZoomGov meetings 

Each Zoom session has a unique link, and a passcode can be 

added for additional security. Furthermore, the meeting host 

can create a “waiting room” for participants, where invitees 

must wait until the meeting host allows them to join the 

session. If an unauthorized individual attempts to join, the 

host can deny that individual from entering the sessions. 

Third party access to 

FTC data 

Both Zoom and its CSP (AWS) have access to FTC data 

collected and maintained through use of the system. Zoom 

employs role-based access controls, and data in the AWS 

cloud is encrypted and may not be accessed without prior 

consent from Zoom. 

8.2 Does the project/system employ the use of automated privacy controls or enhanced 

capabilities designed to support privacy? Explain. 

ZoomGov contains a number of embedded privacy controls and enhanced functions designed 

to support privacy. These features incorporate privacy by design concepts such as the use of 

passcodes, the Waiting Room (host must admit participants individually), “only authenticated 

users can join meetings,” or blocking entry to users from certain countries/regions (to control 

which participants can join and have access to real time meeting content). Additional 

features include a list of all participants present in the meeting (to ensure transparency about 

who has access to real time meeting content); interruptive signals indicating that the meeting 

will be recorded; ability to mute audio, video and to use an alias; controls that prevent 

anyone other than the meeting host from recording the meeting using the built-in recording 

feature (unless the meeting host adds a co-host); and controls that allow the meeting host to 

lock the meeting and prevent additional participants from joining. 

Recorded content that the meeting host does not store locally will be stored in encrypted 

storage in the ZoomGov cloud (a separate FedRAMP-authorized cloud distinct from 

commercial cloud), and will be accessible to FTC account administrators and Zoom support 

engineers if requested by the FTC. FTC account administrators can also choose whether 

cloud recordings can be shared publicly or internal-only—if at all—and otherwise select 

settings to limit access to the recording files. Users can only view their own cloud recordings 

or any cloud recordings that have been shared with the specific user. 

8.3 Has a Privacy Act System of Records Notice (SORN) been published in the Federal 

Register for this system/project? If so, list the applicable SORN(s). 

Not applicable. ZoomGov is not considered to be a Privacy Act System of Records. The 

agency does not use Zoom to collect or maintain agency records retrieved by name or 

personally assigned identifiers. Information, including PII, communicated by or exchanged 

between FTC users and/or outside individuals, may be incorporated into agency records (e.g., 

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investigatory files) subject to the Privacy Act. See the FTC’s list of Privacy Act systems for 

more information, linked to the FTC’s privacy policy, at www.ftc.gov/privacy. 

8.4 How does the project/system ensure that the information is collected, used, stored, 

or disseminated in accordance with stated practices in this PIA? 

The administrative and technical controls described in section 5.2 of this document provide 

assurance that the collection, use, and maintenance of the information will be conducted as 

described in this PIA. This PIA aligns with the FTC’s existing privacy policies and 

procedures. 

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