Pta

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 1 of 10

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

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

PIA@dhs.gov

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

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 2 of 10

PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review:
NAME of Project: Civil Surgeon Designation
Name of Component: US Citizenship and Immigration Services
Name of Project Manager: Kevin Hignam/Meddie Brown
Email for Project Manager: Kevin Higman@dhs.gov/Meddie.brown@dhs.gov
Phone number for Project Manager: (202) 272 8206/ 202 272 1103
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
Other: The civil surgeon designation information collection is submitted to OMB to
comply with the regulatory requirements in the proposed fee rule: U.S. Citizenship and
Immigration Services Fee Schedule, XXXXXXXX.


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

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 10

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 10
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Section 212(a)(1)(A) of the Immigration and Nationality Act (the Act) renders individuals
inadmissible if the individual is afflicted with the statutorily mentioned diseases or medical
conditions. In order to establish that the individual is inadmissible when seeking adjustmetn
of status to a legal permanent resient (and in certain cases, aliens seeking an immigration
benefit) the individual must submit Form I-693, Report of Medical Examination and
Vaccination Record, that is completed by a USCIS designated physician, or "civil surgeon."
The statutory basis for civil surgeons and the medical examination of aliens is contained in
section 232 of the Act and 8 CFR 232.2. To be selected as a civil surgeon, the physician has to
demonstrate that he or she is a licensed physician with no less than 4 years of professional
experience.

Civil surgeons are currently designated by USCIS District Directors. 8 CFR 232.2. The civil
surgeon submits a request for designation by writing to the District Director in the USCIS
jurisdiction in which the civil surgeon would like to complete immigration medical
examinations. Once the designation is granted, the point of contact for the civil surgeon in a
District office creates a file for the civil surgeon that is retained in that office. The point of
contact also forwards the doctors name, office address, office phone number to USCIS
HQ/Customer Service Directorate (CSD) so that the civil surgeon can be included in the
"Civil Surgeon" locator. The civil surgeon locator is a list of designated physicians that can be
accessed by USCIS customers via the IVR telephone system and its website.
The civil surgeon list is maintained on a Data Performance Warehouse (SQL Server 2005
Database) that is supported by Serco, Inc., a contractor for USCIS/CSD. The data stored on
the Data Performance Warehouse and displayed via the IVR telephone system and USCIS's
website (doctor's name, practice, street address, phone number, and local office jurisdiction),
is comparable to information that would be available in a local phone directory. Additional
information contained on the Data Performance Warehouse is: the date of a physician's
designation, the date of the revocation, a brief annotation as to the reason of the annotation;
and the date of any reinstatement. This information is not displayed via the IVR telephone
system and its website; the information is only displayed on the DHS Intranet website and
within USCIS's Adjudicator's Tool Box.
2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 10
Date last updated:
The data for the Data Performance Warehouse is updated continously on an ad hoc
basis.
3.

Could the project relate in any way to an individual? 1
No. Please skip ahead to the next question.
Yes. Please provide a general description, below.
Individual physicians apply for civil surgeon designation.
The data that is stored on the Data Performance Warehouse is comparable to what would be
available in a local phone directory.

4.

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

1

Projects can relate to individuals in a number of ways. For example, a project may include a camera for
the purpose of watching a physical location. Individuals may walk past the camera and images of those
individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a
project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an
individual received chemotherapy.

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 6 of 10
5.

Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:

6.

What information about individuals could be collected, generated or retained?
Name; Address; Phone Number; e-mail; Practice's Name, Pratice's Address, Practice's
Phone and e-mail, URLs, State Medical License Number(s); Adverse actions taken by
the medical license authority (as published on the website of the medical licensing
authority); Name and address of former employer(s); Immigration status (US
citizen/national, lawful permanent resident, nonimmigrant); Signature of the
physician.

USCIS does currently not employ the use of information technology in collecting and
processing information provided with an application for a request for civil surgeon
designation.
Information in the Data Performance Warehouse includes: doctor's name and
practice's, street address, phone number, and local office jurisdiction; date of
designation, date of revocation, and the reason for revocation, as well as the date of
reinstatement.

The Data Performance Warehouse has not undergone a certification and accredition
process under the USCIS ITLM process.
7.

If this project is a technology/system, does it relate solely to infrastructure? [For example, is
the system a Local Area Network (LAN) or Wide Area Network (WAN)]?
No. Please continue to the next question.
Yes. Is there a log kept of communication traffic?
No. Please continue to the next question.
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 10
Payload Please describe the data that is logged.

8.

Can the system be accessed remotely?
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
No.
Yes.

9.

Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes. For the designation process: currently, a phyisican seeking civil surgeon designation will
apply by sending an informal request for civil surgeon designation to the District Director. The
request is made either in paper or via e-mail (if available). The information is stored in either a
paper file, or in computer file created by the local point of contact for civil surgeons. Information,
such as name, address, and phone number, date of acceptance as a civil surgeon, and if, any
annotation as to the reason for recovation or removal from the list (once the revocation of the
desigation or the removal is requested) is transmitted via e-mail to a POC at USCIS HQ, who
transmits the information to Serco Inc., a DHS contractor. Serco Inc. creates a roster with
information relating to the entries mentioned above. The list is stored in the "Data Performance
Warehouse" that is set up by Serco, Inc.
In relation to the Data Performance Warehouse: The response to the question is no.
Serco, Inc. transmits periodic updates to the civil surgeon list to Verizon Buisness (for inclusion
on the USCIS telephone help line), IBA (for inclusion on the USCIS website), and the USCIS OIT
(for inclusion on DHS Online). There is no direct connection between the Data Performance
Warehouse and the other entities; the updates are performed by transmitting commadelimited,
text files to these entities. There is no direct connection between the Data Performance
Warehouse and the USCSI IT systems. Only designated parties from Serco, Inc. and USCIS can

2

Personally Identifiable Information is information that can identify a person. This includes; name, address, phone
number, social security number, as well as health information or a physical description.

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 8 of 10
gain access to the front end web-server for the Data Performance Warehouse to view the data.
Access requires a unique user ID and password.
10.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems3?
No
Yes. Please list:

11.

Are there regular (ie. periodic, recurring, etc.) data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation4?
Yes.
No. Once a year, Serco, Inc. verifies that the information in the Data Performance
Warehouse is accurate by contacting every civil surgeon listed in the Data Performance
Warehouse. This will ensure that the information contained in USCIS' telephone system
for civil surgeons and USCIS' website (Civil Surgeon Locator) is accurate. If a civil
surgeon cannot be reached, despite several attempts to contact the civil surgeon, the civil
surgeon will be deleted from the Data Peformance Warehouse.

12.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.
Yes. Please indicate the determinations for each of the following:

3

Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes.
Often, these systems are listed as “interconnected systems” in TAFISMA.
4
This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 9 of 10
Availability:

Low

Moderate

High

Undefined

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 10 of 10
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: March 24, 2010
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System
National Security System
Legacy System
HR System
Rule
Other: Form
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: USCIS CLAIMS 3 PIA
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/USCIS-007
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS