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 10, 2010
Page 1 of 6
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 from the component Privacy Office, 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 DHSConnect 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 10, 2010
Page 2 of 6
PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review:
Name of Project: Form I-361, Affidavit of Financial Support and Intent to Petition for Legal
Custody for Public Law 97-359 Amerasian
System Name in TAFISMA: Not applicable
Name of Component: United States Citizenship and Immigration Services
Name of Project Manager: Vicente F. Lopez
Email for Project Manager: vicente.f.lopez@uscis.dhs.gov
Phone Number for Project Manager: (202) 272-1080
Type of Project:
Information Technology and/or System. ∗
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
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 10, 2010
Page 3 of 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Form I-361 is to be filed in support of Form I-360, Petition to Classify Public Law 97-359
Amerasian as the Child, Son, or Daughter of a United States Citizen. Public Law 97-359 (Act
of 10/22/82) provides for the immigration to the United States of certain Amerasian children.
In order to qualify for benefits under this law, an alien must have been born in Cambodia,
Korea, Laos, Thailand, or Vietnam after December 31, 1950, and before October 22, 1982, and
have been fathered by a U.S. citizen. Form I-361 is filed as an agreement to provide financial
support for a five year period for an Amerasian or to petition a court for legal custody of an
Amerasian under 18 years of age. The petitioner must swear to, or affirm the affidavit before
an officer of USCIS if he is in the United States, or a U.S. immigration or consular officer if
outside of the U.S.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: 1983
Date last updated: April 30, 2012
This is a request to extend the use of Form I-361(OMB No. 1615-0021) under the
Paperwork Reduction Act, which is set to expire on April 30, 2012. The form is being
extended with no revisions.

3.

From whom 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.

4.

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:

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 10, 2010
Page 4 of 6
Form-361 does not request or collect social security numbers.
5.

What information about individuals could be collected, generated or retained?
Form I-361 collects the following data elements from the individual filing the affidavit:
names, addresses, date, city, and country of birth, citizenship or naturalization number, Alien
Number (A-Number), annual income, savings, personal property worth, names of
dependents, age of dependents, names of previously submitted visa beneficiaries, employer,
employer's address beneficiary's name, date of birth, A-Number, address.

6.

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.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 1?
No.
Yes.
Please list:

8.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.

1

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.

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 10, 2010
Page 5 of 6
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

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

Privacy Threshold Analysis
Version date: June 10, 2010
Page 6 of 6

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: April 12, 2012
Name of the DHS Privacy Office Reviewer: Catherine Bauer
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.
PIA is required.
System covered by existing PIA: DHS/USCIS/PIA-003 IDDMP
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/USCIS/ICE/CBP-001 A-File
New SORN is required.
DHS PRIVACY OFFICE COMMENTS