Pta

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 1 of 11

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:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
PIA@hq.dhs.gov

Upon receipt from your 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@hq.dhs.gov, phone: 202-343-1717.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 2 of 11

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Form I-694, Notice of Appeal of Decision Under Section 210 or 245A of the
Immigration and Nationality Act

Component:

U.S. Citizenship and
Immigration Services (USCIS)

Office or
Program:

FOD

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Update

Date first
developed:
Date of last PTA
update

Click here to enter a date.

Pilot launch
date:

Click here to enter a date.

July 13, 2010

Pilot end date:

Click here to enter a date.

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Click here to enter text.

Office:

Click here to enter text.

Title:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 3 of 11

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Updated PTA
USCIS Instructions: Please provide a brief overview of the Form to understand the purpose, mission
and justification of collecting the requested information. Include the following:


Description of the purpose of the form



A brief description of who the form collects information on and how the information is
collected



Description of the information technology used to support this project



Description of the responsible Program Office



Description of any authorizing legislation



Description of how the form relates to the USCIS’ mission

Example: The USCIS Genealogy Program provides access to historical immigration and naturalization
records of deceased immigrants to family historians and other researchers through two fee-based
services:
• Index Search: Form G-1041, Genealogy Index Search Request is used to request a search of
USCIS historical databases. Request for searches of these databases are used to determine
whether any records pertaining to a subject exists, and, if such records exist, to collect record
citations (i.e., USCIS file numbers). The fee for an index search is $20.00.
• Record Copy Request: Form G-1041A, Genealogy Records Request is used to obtain copies of
USCIS historical records. Researchers with valid record citations, gained through the index
search (Form G-1041) or through independent research, may request microfilm and/or paperbased copies of genealogy records. The fee for a record copy request depends on the record type
but varies between $20.00 -$35.00.
This form can be filled out and submitted to USCIS by researchers seeking records of their ancestry for
genealogical or family history purposes; historians or social scientists seeking historical records of
persons that can be identified by name, date of birth and place of birth; or a researcher involved in their
location.
This is an update of the previously approved PTA. There is one change since the last PTA; the collection
of USCIS online account number.
This form will be used by USCIS in considering appeals of denials or termination of temporary and
permanent residence status by legalization applicants and special agricultural workers, under sections 210
and 245A of the Immigration and Nationality Act, and related applications for waiver of grounds of
inadmissibility.
This form collects information on legalization and special agricultural worker appellants, interpreters, and
preparers.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 4 of 11

This project continues to use CLAIMS 3 to support this project. This form is stored in the A-file.
The Field Operations Directorate is the business owner for this form. The Administrative Appeals Office
is responsible for reviewing and determining whether to grant or deny this benefit request.
USCIS is authorized to collect Form I-694 pursuant to the Immigration and Nationality Act, section
245A(f)(3) and Title 8 Code of Federal Regulations, part 103.3(a)(3) and 103.3(a)(4).
The USCIS mission is to administer immigration benefits. This form enables USCIS to determine
whether to grant an immigration benefit.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology please stop here and contact the DHS
Privacy Office for further guidance.
USCIS Instructions: Please check “None of the
above” since this PTA is intended to cover the form
and does not relate to any technologies.
3. From whom does the Project or
Program collect, maintain, use, or
disseminate information?
Please check all that apply.

Closed Circuit Television (CCTV)
Social Media
Web portal 1 (e.g., SharePoint)
Contact Lists
None of these

This program does not collect any personally
identifiable information 2
Members of the public
DHS employees/contractors (list components):

USCIS Instructions: Please check the appropriate
box to indicate the source of information for the
form.

Contractors working on behalf of DHS
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?
1

Informational and collaboration-based portals in operation at DHS and its components that collect, use, maintain, and share
limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who
seek to gain access to the portal.
2
DHS defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the
identity of an individual to be directly or indirectly inferred, including any information that is linked or linkable to that individual,
regardless of whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to
the Department. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial
harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 5 of 11

USCIS Instructions: Identify (1) the categories of individuals for whom information is collected, and (2)
for each category, list all information, including PII that is collected and stored by the form. Please indicate
if the form collects Social Security Numbers by either checking “Yes” or “No.” The response should also
include the purpose of the collection and the legal authority to collect such information.
Example: PII could include, but is not limited to: name, date of birth, mailing address, telephone number,
social security number, e-mail address, zip code, facsimile number, mother’s maiden name, medical
record number, bank account number, health plan beneficiary number, any other account numbers,
certificate/license number, vehicle identifier including license plate, marriage record, civil or criminal
history information, medical records, device identifiers and serial numbers, education record, biometric
identifiers, photographic facial image, or any other unique identifying number or characteristic.
The authority to collect information in this form is set forth in the Immigration and Nationality Act, 8
U.S.C. §§ 1103, 1158, 1225, 1228, and Title II of Public Law 105-100 and in the implementing
regulations found in volume 8 of the Code of Federal Regulations (CFR). The SSN information collected
within the form I-000 application is used to assist the DHS in enforcing the immigration laws of the
United States by providing timely and accurate information about persons who are subject to those laws.
(1) This form is filed by individuals (appellants) appealing the denial of an immigration benefit under
INA section 210 or 245A. Interpreter and preparer information may be collected also.
(2) Information collected from legalized and special agricultural work (appellants) includes:
• A-number
• Name (first name, last name)
• Address
• Contact Information (daytime phone, mobile phone, and email address)
• USCIS Online Account Number
• Email address
(3) Interpreter
•

Name (first name, last name)

•

Business/Organization name

•

Mailing address

•

Contact information (daytime phone, mobile phone, and email address)

(4) Preparer
•

Name (first name, last name)

•

Business/Organization name

•

Mailing address

•

Contact information (daytime phone, mobile phone, and email address)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 6 of 11

4(a) Does the project, program, or system
retrieve information by personal identifier?
USCIS Instructions: Please check “Yes” and
include the identifiers(s) used to retrieve
information from case management systems used
to process this form.
4(b) Does the project, program, or system
use Social Security Numbers (SSN)?
4(c) If yes, please provide the specific legal
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
an information 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 next question.
Yes. If yes, please list all personal identifiers
used: Name, A-Number

No.
Yes.
Click here to enter text.

Click here to enter text.

No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

USCIS Instructions: Please check “No” since
this PTA is intended to cover the form and does
not relate to an information technology.
4(f) If header or payload data 3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?

No.
Yes. If yes, please list:
CLAIMS 3

3

When data is sent over the Internet, each unit transmitted includes both header information and the actual data being sent. The
header identifies the source and destination of the packet, while the actual data is referred to as the payload. Because header
information, or overhead data, is only used in the transmission process, it is stripped from the packet when it reaches its destination.
Therefore, the payload is the only data received by the destination system.
4
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 Xacta.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 7 of 11

USCIS Instructions: Please check “Yes” and
include the information technology system that
supports this form.
6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?
USCIS Instructions: Please check “No” if the
form itself is maintained in a USCIS system and
not shared externally. However, if this form is
processed and maintained in an external system
(e.g. a Department of State system) please include
the relevant IT system). Additionally, if the form
itself is shared externally, please check “Yes” and
include the name of the recipient.
6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?

No.
Yes. If yes, please list:
Click here to enter text.

Choose an item.
Please describe applicable information sharing
governance in place:

No.
Yes. If yes, please list: USCIS Privacy
Awareness Training
CLAIMS 3 Training

USCIS Instructions: Please check “Yes” and
include the relevant trainings USCIS staff
complete.
8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have
requested access to their PII?
USCIS Instructions: Please check “No” since
this is a question solely related to IT systems.
9. Is there a FIPS 199 determination? 4
4

Not applicable.
No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained:

Not applicable.

FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 8 of 11

Unknown.
USCIS Instructions: Please check “No” since
this is a question solely related to IT systems.

No.
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

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Kim Mott

Date submitted to Component Privacy
Office:

April 15, 2016

Date submitted to DHS Privacy Office:

May 11, 2016

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
This is an update of the previously approved PTA. There is one change since the last PTA; the collection
of USCIS online account number. This form will be used by USCIS in considering appeals of denials or
termination of temporary and permanent residence status by legalization applicants and special
agricultural workers, under sections 210 and 245A of the Immigration and Nationality Act, and related
applications for waiver of grounds of inadmissibility. This form collects information on legalization and
special agricultural worker appellants, interpreters and preparers. This project continues to use CLAIMS 3
to support this project. This form is stored in the A-file.
The Privacy Act Statement (PAS) has been reviewed by the Form Sponsor to verify accuracy. It has been
sent to the Office of Chief Counsel for review.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 9 of 11

The Office of Privacy recommendation is this is a privacy sensitive form with coverage under existing
PIAs/SORNs.
PIA
•

DHS/USCIS/PIA – 016(a), Computer Linked Application Information Management System
(CLAIMS 3) which covers name, address, telephone number, DOB, SSN, citizenship
information, immigration status (which includes the A-number), and unique identifying numbers
(USCIS ELIS account numbers) for the appellant. This PIA covers name, business, mailing
address, email address, phone number of the interpreter and preparer. This is the updated PIA that
will be posted on the web site soon.

SORN
•

DHS/USCIS/ICE/CBP-001, Alien File, Index and National File Tracking System of Records (78
FR 69864) since this is where the form is stored. It covers the appellant, preparer and
representatives who assist the individual during benefit and enforcement proceeding and includes
name, address, phone number and email addresses.

•

DHS/USCIS-007, Benefits Information System (73 FR 56596) which covers processing all
immigrant and non-immigrant benefits applications for petitioners including name, A-number,
addresses, telephone numbers, and DHS issued card serial numbers. Preparer information covered
includes name, mailing address, and telephone number.

(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Max Binstock

PCTS Workflow Number:

1123538

Date approved by DHS Privacy Office:

May 11, 2016

PTA Expiration Date

May 11, 2019
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

Form/Information Collection
If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 10 of 11

New information sharing arrangement is required.
DHS Policy for Computer-Readable Extracts Containing Sensitive PII
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.
System covered by existing PIA
PIA:

If covered by existing PIA, please list: DHS/PIA/USCIS-016(a) Computer Linked
Application Information Management System (CLAIMS 3) and Associated Systems
System covered by existing SORN

If covered by existing SORN, please list:
-DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of
Records, November 21, 2013, 78 FR 69864
-Forthcoming DHS/USCIS-007 Benefits Information System
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS is submitting Form I-694 PTA in considering appeals of denials or termination of temporary and
permanent residence status by legalization applicants and special agricultural workers.
SORN:

PRIV agrees that Form I-694 is a privacy sensitive system that requires PIA coverage because Form I-694
collects PII from members of the public. Specifically, it collects information on legalization and special
agricultural worker appellants, interpreters, and preparers.
DHS/USCIS-016(a) CLAIMS 3 provides coverage because it supports and maintains officer casework
documentation and tracking for most benefit requests. DHS/USCIS-016(a) covers name, address,
telephone number, DOB, SSN, citizenship information, immigration status (which includes the Anumber) for the appellant. CLAIMS 3 also provides coverage for name, business, mailing address, email
address, phone number of the interpreter and preparer.
PRIV finds Form I-694 is covered by the DHS/USCIS/ICE/CBP-001 SORN, which covers maintenance
of records collected in the A-File.
Form I-694 will be covered by the forthcoming DHS/USCIS-007 SORN, which covers automated
processing of immigrant and nonimmigrant benefit petitions and applications.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 11 of 11