Draft 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 8

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 8

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: September 14, 2010
NAME of Project: E-Verify Self Check
Name of Component: US Citizenship and Immigration Services
Name of Project Manager: Michael Mayhew
Email for Project Manager: michael.mayhew@dhs.gov
Phone number for Project Manager: 202 443-0021
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
Other:



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

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 8
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Currently, individuals are verified through the E-Verify process after they have been hired by
an E-Verify employer. Employees who receive a Tentative Non-Confirmation (TNC) may
have to take time off from work to resolve an issues that led to the TNC. In some limited
instances, employers do not follow E-Verify rules and they terminate employees rather than
work with them to resolve the TNC. There is no capability for an individual to determine
what the result of an E-Verify query would be, until they have been hired and run through
the system by their new employer.
The Self Check Process will give workers the ability to check their own work authorization
status by querying E-Verify's Verification Information System (VIS) at anytime from from
any computer that has web access. This will allow employees to proactively address any
issues that could lead to a TNC, thereby reducing the overal number of TNC's, as well as
those leading to unlawful terminations.
The E-Verify Self Check process works in the same manner as the normal employer E-Verify
process. An individual will submit the same information required for an E-Verify query and
it will then be checked against VIS databases to determine the individual's work
authorization status. This process has been described and approved as part of the E-Verify
System of Records Notice (SORN) and Privacy Impact Assessments (PIA).
Before the Self Check process begins the individual must go through an identity proofing
process to help ensure that the identifying information submitted actually relates to the
individual submitting the query. The Self Check application will use a third party vendor
that will collect certain identifying information such as the individuals name, date of birth,
home address, and optionally the social security number and search various public databases
returning a number of knowledge-based identity proofing questions to the individual. The
optional use of the social security number will assist to help to identify individuals that may
not have a significant credit history. These questions may concern previous addresses or
phone numbers, financial account information, court record information, and other publicly
accessible data. The individuals will be offered a number of questions, if they are able to
respond to the questions in a satisfactory manner they will be allowed to proceed to the Self
Check screen which will be pre-populated with the name entered during the identity
proofing step. If they are unable to answer the questions satisfactorily they will not be able to
proceed and run an E-Verify Self Check query and they must rely on the employer running
the E-Verify query.
In later iterations of Self Check it is assumed that a process will be developed for individuals
to have additional options to prove their identity if they are unable to successfully pass the
identity proofing process using the knowledge-based questions.

2.

Status of Project:

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 8
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated:

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.
It allows individuals to query their own work authorization status at anytime that is
convenient for them. This allows them time to resolve potential issues before an employer
runs their information through E-Verify and minimizes the likelihood that they will receive a
TNC.

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 5 of 8
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:
Collecting the SSN is part of the E-Verify process as described in the E-Verify PIA and
SORN. The optional use of the social security number during the authentication process will
assist to help to identify individuals that may not have a significant credit history.

6.

What information about individuals could be collected, generated or retained?
The exact requirements have not yet been determined but it is expected that the
application will collect some combination of name, date of birth, home address, and
optionally the social security number as part of the authentication process. Other
data elements are collected as described in the E-Verify PIA and SORN.

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
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. Publicly accessible.

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 8
Yes.

9.

Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes. Personal information is transported from the publicly accessible website to both VIS and
the 3rd party authentication organization.

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.

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:
Confidentiality:

2

Low

Moderate

High

Undefined

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.
3
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 7 of 8

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

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

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 8 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: September 20, 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:
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:
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN:
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS