PIA 013a

Privacy Impact Assessment
for the

Fraud Detection and National Security Data
System (FDNS-DS)
DHS/USCIS/PIA-013(a)
May 18, 2016
Contact Point
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
202-272-8000
Reviewing Official
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security
202-343-1717

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Abstract
The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services
(USCIS), developed the Fraud Detection and National Security Data System (FDNS-DS) as the
primary case management system used to record requests and case determinations involving
immigration benefit fraud, public safety, and national security concerns. Since its initial
deployment, USCIS has incorporated a new screening functionality into FDNS-DS, known as
ATLAS, to more effectively identify and review cases involving fraud, public safety, and national
security concerns. 1 USCIS is updating and reissuing the entire FDNS-DS Privacy Impact
Assessment (PIA), originally published on June 29, 2008, to capture these updates.

Overview
Every year, U.S. Citizenship and Immigration Services (USCIS) receives nearly 6.4 million
applications for immigration benefits or service requests. USCIS is committed to ensuring the
integrity of the United States (U.S.) immigration system. An integral part of USCIS’s delegated
authority to adjudicate benefits, petitions, or requests, and to determine if individuals are eligible
for benefit or services, is to conduct screenings (i.e., background, identity, and security checks) on
forms filed with the agency. USCIS Fraud Detection and National Security Directorate (FDNS)
developed the Fraud Detection and National Security – Data System (FDNS-DS) to record, track,
and manage the screening processes related to immigration applications, petitions, or requests with
suspected or confirmed fraud, public safety, or national security concerns. FDNS also uses FDNSDS to identify vulnerabilities that may compromise the integrity of the legal immigration system.
The 2014-2018 Department of Homeland Security (DHS) Strategic Plan states that DHS
will enforce and administer the nation’s immigration laws by “ensuring that only eligible
applicants receive immigration benefits through expanded use of biometrics, a strengthening of
screening processes, improvements to fraud detection, increases in legal staffing to ensure due
process, and enhancements of interagency information sharing.” 2 Recent events highlight the
importance of screening immigration benefit applicants for fraud, public safety, and national
security concerns. Within FDNS-DS, FDNS developed a screening module known as ATLAS.
ATLAS’s event-based screening capability increases the timeliness and quality of fraud referrals.
For the purpose of this PIA, the term FDNS-DS encompasses both the case management system
and the screening module, ATLAS.

1
2

ATLAS is not an acronym.
Department of Homeland Security. “Fiscal Years 2014 – 2018 Strategic Plan.”

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FDNS-DS receives, tracks, and records information through the following processes:
screening, referrals made to FDNS, administrative investigations, and through conducting studies
related to benefit fraud and trends 3, as detailed below.
Screening and Referrals to FDNS
The types of screening performed on immigration forms vary by the benefit/request type.
In general, USCIS conducts background checks 4 to obtain relevant information in order to render
the appropriate adjudicative decision with respect to the benefit or service sought, identity checks
to confirm the individual’s identity and combat potential fraud, and security checks to identify
potential threats to public safety or national security. Standard checks may include:
•

Biometric fingerprint-based checks:
1. Federal Bureau of Investigation (FBI) Fingerprint Check
2. DHS Automated Biometric Identification System (IDENT) Fingerprint
Check 5
3. Department of Defense Automated Biometric Identification System (ABIS)
Fingerprint Check 6

•

Biographic name-based checks:
1. FBI Name Check
2. TECS 7 Name Check

USCIS uses several systems to support the checks identified above, which are described in
detail in the Immigration Benefits Background Check Systems 8 and Customer Profile
Management Service 9 PIAs, as well as the PIAs associated with USCIS’s case management
systems. As mentioned in those PIAs, USCIS adjudications staff must query multiple systems, in
3

See DHS/USCIS/PIA-013-01 FDNS Program, available at www.dhs.gov/privacy, for more information on the
administrative inquiry process, adjudication, and BFA Process. FDNS completes administrative investigations to
obtain relevant information needed to render the appropriate adjudicative decision.
4
During the adjudication process, USCIS conducts four different background checks, two biometric fingerprintbased and two biographic name-based, which are discussed in detail in the Immigration Benefits Background Check
Systems (IBBCS) PIA. See DHS/USCIS/PIA-033 IBBCS, available at www.dhs.gov/privacy.
5
See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.
6
For certain benefit types in which the beneficiary has a higher likelihood of having previously been fingerprinted
by the U.S. military, USCIS conducts checks against the Department of Defense’s Automated Biometric
Identification System, as described in the Customer Profile Management System (CPMS) PIA. See
DHS/USCIS/PIA-060 CPMS, available at www.dhs.gov/privacy.
7
See DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing (TECS), available at
www.dhs.gov/privacy.
8
See DHS/USCIS/PIA-033 IBBCS, available at www.dhs.gov/privacy.
9
See DHS/USCIS/PIA-060 CPMS, available at www.dhs.gov/privacy.

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some cases manually. Through the development of a screening module within FDNS-DS, known
as ATLAS, the need to independently query each system is greatly reduced, thereby streamlining
the screening process and limiting the privacy risks associated with using multiple systems.
ATLAS interfaces with other systems in order to automate system checks and promotes consistent
storage, retrieval, and analysis of screening results to enable FDNS to detect and investigate fraud,
public safety, and national security concerns more timely and effectively. The specific system
interfaces that enable screening through ATLAS are detailed at Appendix A.
Within FDNS-DS, ATLAS’s automated, event-based screening is triggered when:
1. An individual presents him or herself to the agency (e.g., when USCIS receives an
individual’s benefit request form 10 or while capturing an individual’s 10-fingerprints
at an authorized biometric capture site, for those forms that require fingerprint checks);
2. Derogatory information is associated with the individual in one or more DHS systems;
or
3. FDNS performs an administrative investigation.
ATLAS receives information from the individual’s form submission and from the biographic and
biometric-based checks listed above. That information is screened through a predefined set of rules
to determine whether the information provided by the individual or obtained through the required
checks presents a potential fraud, public safety, or national security concern. The rules help
standardize how information is analyzed and help to detect patterns, trends, and risks that are not
easily apparent from the form submissions themselves.
Previously, FDNS-DS received information primarily through manual referrals of cases
from USCIS adjudications staff. Since the development of ATLAS, cases can now be referred to
FDNS for administrative investigation in the following manners:
Referrals through System Generated Notifications (SGNs)
The screening process described above automates the process of referring cases to FDNS
for review. Certain events, such as when USCIS receives a benefit request form or the 10-print
capture of an individual’s fingerprints at a biometric capture center, trigger rules-based screening.
If the benefit request form or biometric capture matches a rule, ATLAS produces an SGN, which
is elevated in FDNS-DS for manual review. Once an SGN is produced, a specially trained FDNS
Officer, known as a Gatekeeper, conducts a manual review of the SGN for validity, determines
whether it is “actionable” or “inactionable,” and, if “actionable,” triages the SGN for further action.
If an SGN is “actionable,” it enters the formal FDNS-DS case management process. An SGN
found to be “inactionable” may be closed without further action. The SGN itself is not considered
derogatory. SGNs help FDNS Officers to detect potential threats earlier in the immigration benefit
10

See DHS/USCIS/PIA-061 Benefit Request Intake Process, available at www.dhs.gov/privacy.

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application process, to demonstrate the fidelity of the individual’s biographic and biometric
information, and to identify discrepancies more efficiently.
Fraud Tip Referrals
Members of the public and other government agencies can voluntarily submit a fraud tip
to USCIS directly by emailing ReportFraudTips@uscis.dhs.gov. In the future, a static page will
be available at www.uscis.gov, where a link to the mailbox will be provided. The webpage lists
suggested fields that FDNS has deemed useful when processing the tip. The list serves merely as
a suggestion; a fraud or tip reporter can include as much or as little information as he or she wishes.
More information about the fraud tip reporting process is described in Appendix H to the FDNS
Directorate PIA. 11
Upon receiving a tip, FDNS evaluates the tip to determine if it is “actionable” or
“inactionable” for investigation. If FDNS deems the tip “actionable,” FDNS manually inputs the
information into FDNS-DS and prepares the tip for an administrative investigation.
Manual Referrals
USCIS adjudications staff can make manual referrals to FDNS through FDNS’s Intranet
Fraud Referral System (iFRS). Through this process, adjudications staff complete a fillable
electronic form using the USCIS SharePoint Enterprise Collaboration Network (ECN). 12 FDNS
Officers review the referrals and determine if the referral is “actionable” or “inactionable” and
manually enter the information into FDNS-DS. If “actionable,” FDNS prepares the referral for
administrative investigation.
Administrative Investigations
If FDNS determines an administrative investigation is necessary, FDNS conducts further
checks to verify information prior to an adjudicative decision on the immigration benefit or service
requested, to include resolving any potential fraud, public safety, or national security concerns. In
conducting an administrative investigation, 13 FDNS may perform one, or a combination, of the
following:

11

•

Research in Government and commercial databases and public records;

•

Internet searches of open source information;

•

Searches of publicly available information, including, but not limited to, social
media sites;

See DHS/USCIS/PIA-013-01 FDNS Directorate, available at www.dhs.gov/privacy.
See DHS/ALL/PIA-059 Employee Collaboration Tools, available at www.dhs.gov/privacy.
13
See DHS/USCIS/PIA-013-01 FDNS Directorate, available at www.dhs.gov/privacy, for more information on
FDNS administrative investigations.
12

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•

File reviews;

•

Telephone calls;

•

Site visits;

•

Interviews of applicants, beneficiaries, petitioners, and others;

•

Requests for evidence;

•

Administrative subpoenas;

•

Requests for assistance from law enforcement agencies;

•

Overseas verifications; and

•

Referral to law enforcement agencies.

FDNS may perform administrative investigations or work with partner agencies, as appropriate,
and ultimately produces findings to sufficiently inform adjudications.
Federated Immigration Screening and Application Report (FISAR)
The Federated Immigration Screening and Application Report (FISAR) within FDNS-DS
is an advanced search functionality that allows FDNS-DS users to view the entire screening history
on an individual, including records of standard checks, any SGNs produced by ATLAS that relate
to the individual, and administrative investigations performed. If there are SGNs in the individual’s
screening history, the FDNS-DS user can easily determine the status of those SGNs (e.g., pending
or triaged). The gatekeeping process described above provides manual oversight to ensure that
SGNs produced by the system are valid and that they relate to the individual.
Enhanced Analytical Capabilities
FDNS enhanced ATLAS with analytical capabilities to enable users to more easily query
and visualize data within the system and to identify individuals who are filing for immigration and
naturalization benefits who may potentially be engaging in fraudulent behavior or pose a risk to
public safety or national security. During the screening process, ATLAS analyzes the results of
biographic and biometric checks, applies rules, and performs link and forensic analysis and entity
resolution among data received from multiple systems. ATLAS assists in confirming individuals’
identities when individuals are potentially known by more than one identity by comparing the
identity information provided by the individual with identity information in other systems checked
against the background, identity, and security check process. As an example, ATLAS can
determine if an individual has applied for benefits using multiple biographic identities or aliases.
ATLAS also visually displays linkages or relationships among individuals to assist in identifying
non-obvious relationships among individuals and organizations with a potential nexus to criminal

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or terrorist activities. The results of this analysis may be produced and elevated in FDNS-DS in
the form of an SGN or obtained through FISAR.
ATLAS’s analytical capabilities do not alter the source data. All legal and policy controls
around the source data remain in place.
USCIS is continuing to enhance its screening processes by incorporating seven core
capabilities into ATLAS: (1) Predictive Analytics; (2) Link and Forensic Analysis; (3)
Unstructured and Structured Analytics; (4) Intelligent Investigative Case Management; (5)
Operational Decision Management; (6) Information Sharing and Collaboration; and (7) Entity
Analytics. Before new analytical capabilities are deployed within FDNS-DS/ATLAS, the USCIS
Office of Privacy will review them to determine additional privacy requirements, which may
include updating or re-issuing FDNS PIAs or SORNs.
Types of Information Collected and Stored within FDNS-DS
The following information is collected and stored in FDNS-DS:
•

Information collected during screening (i.e., background, identity, and security check
processes) to include information provided by the individual on a benefit request form, in
response to a request for evidence, or during an interview; derogatory information received
in response to checks; and audit trails or logs reflecting the history of checks conducted on
the individual;

•

Information collected during the adjudicative and administrative investigation process;

•

USCIS investigative referrals to law enforcement agencies (LEA) of suspected or
confirmed fraud, public safety issues, or national security concerns;

•

Referrals and leads from other government agencies and LEAs related to individuals with
an immigration history with USCIS;

•

Information collected during response to a Request For Information (RFI) from law
enforcement and intelligence agencies;

•

Referrals from the public or other governmental entities or fraud case referrals from the
Benefit Fraud Assessment (BFA) process (“other referrals”);

•

Information from cases that are selected for study of benefit fraud rates or trends;

•

Adverse information identified by USCIS from applications, administrative files,
interviews, written requests for evidence (RFE) or site visits; resolution of any of the
above-described categories of adverse information; and

•

Adjudicative summaries and decisions.

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This PIA generally covers the privacy risks and mitigation strategies associated with the
FDNS-DS system and its screening (rules-based referrals) and case management capabilities.
USCIS will maintain operationally sensitive appendices to this PIA that will analyze privacy risks
and mitigation strategies associated with enhanced analytical capabilities that have been approved
for use within FDNS-DS.
The privacy risks and mitigation strategies associated with the overall administrative
investigation process are described in the FDNS Directorate PIA. Additionally, other published
USCIS PIAs available http://www.dhs.gov/privacy cover the benefit request intake process,
benefit request form analysis and case management, as well as the collection of biographic and
biometric information that is used as part of the screening process. These published PIAs provide
an in-depth discussion of these separate processes and evaluate the privacy risks and mitigation
strategies built into each process.

Section 1.0 Authorities and Other Requirements
1.1

What specific legal authorities and/or agreements permit and
define the collection of information by the project in question?

The legal authority to collect this information comes from the Immigration and Nationality
Act 8 U.S.C. Section 1101 et seq. In addition, the Secretary of Homeland Security in Homeland
Security Delegation No. 0150.1 delegated the following authorities to USCIS:
“(H) Authority under section 103(a)(1) of the Immigration and Nationality Act of 1952, as
amended (INA), 8 U.S.C. §1103(a)(1), to administer the immigration laws (as defined in
section 101(a)(17) of the INA).
Authority to investigate alleged civil and criminal violations of the immigration laws,
including but not limited to alleged fraud with respect to applications or determinations
within the Customs and Border Protection (CBP) or the CIS and make recommendations
for prosecutions, or other appropriate action when deemed advisable.”

1.2

What Privacy Act System of Records Notice(s) (SORN(s)) apply to
the information?

Information collected, maintained, used, and disseminated by FDNS-DS is covered under
the following SORNs:
•

DHS/USCIS-006 Fraud Detection and National Security Records (FDNS), August
8, 2012 (77 FR 47411)

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o Final Rule for Privacy Act Exemptions, August 31, 2009 (74 FR
45084)
•

1.3

DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking
System of Records, September 18, 2017 (82 FR 43556)

Has a system security plan been completed for the information
system(s) supporting the project?

Yes. FDNS-DS was approved for entrance into the DHS Ongoing Authorization Program
on August 26, 2014. A system privacy plan is pending the completion of this PIA.

1.4

Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?

Yes. NARA approved the FDNS-DS retention schedule, N1-566-08-18. FDNS will retain
the records 15 years from the date of the last interaction between FDNS personnel and the
individual for records maintained in FDNS-DS. Records related to an individual’s A-File will be
transferred to the A-File and maintained under the A-File retention period. USCIS maintains
records on individuals and all of their immigration transactions and law enforcement and national
security actions (if applicable), in the A-File. A-File records are permanent records in both
electronic and paper form. USCIS transfers A-Files to the custody of NARA 100 years after the
individual’s date of birth, in accordance with N1-566-08-011.

1.5

If the information is covered by the Paperwork Reduction Act
(PRA), provide the OMB Control number and the agency number
for the collection. If there are multiple forms, include a list in an
appendix.

Almost all of the information within FDNS-DS is originally submitted on a benefit request
form that is subject to the PRA. However, there are no forms associated specifically with the
collection of information in FDNS-DS. Please see the benefit request PIAs and Appendices for a
comprehensive list of the various forms that cover the initial collection of information from the
individual. 14

14

See DHS/USCIS/PIA-061 Benefit Request Intake Process, available at www.dhs.gov/privacy.

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Section 2.0 Characterization of the Information
The following questions are intended to define the scope of the information requested or
collected, as well as reasons for its collection.

2.1

Identify the information the project collects, uses, disseminates, or
maintains.

Due to the nature of the information within FDNS-DS, FDNS-DS contains sensitive
personally identifiable information (SPII). Depending upon the category of information being
collected in or attached to an FDNS-DS record, the system may collect the following SPII:
Information about individuals may include, if applicable:
•

Full name;

•

Alias(es);

•

Physical and Mailing Addresses;

•

Alien Number (A-Number);

•

USCIS Online Account Number;

•

Social Security number (SSN);

•

Date of birth;

•

Nationality;

•

Country of citizenship;

•

Place of birth;

•

Gender;

•

Marital status;

•

Military status;

•

Phone numbers;

•

Email address;

•

Immigration status;

•

Government-issued Identification (e.g., passport, driver’s license):
o Document Type;
o Issuing Organization;

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o Document Number; and
o Expiration Date.
•

Signature;

•

Other Unique Identifying Numbers (e.g., Department of State (DOS)-issued Personal
Identification Number, ICE Student and Exchange Visitor Number, USCIS E-Verify
Company Identification Number);

•

Arrival/Departure information;

•

Immigration history (e.g., citizenship/naturalization certificate number, removals,
explanations);

•

Family relationships (e.g., parent, spouse, sibling, child, other dependents) and
Relationship Practices (e.g., polygamy, custody, guardianship);

•

USCIS Receipt/Case Number;

•

Personal background information (e.g., involvement with national security threats,
criminal offenses, Communist party, torture, genocide, killing, injuring, forced sexual
contact, limiting or denying others religious beliefs, service in military or other armed
groups, work in penal or detention systems, weapons distribution, combat training);

•

Medical information;

•

Travel history;

•

Education history;

•

Work information (contact information, position and relationship to an Organization,
degree(s), membership(s), accreditation(s), license(s) identification numbers);

•

Work history;

•

Bank account or financial transaction history;

•

Supporting documentation as necessary (e.g., birth, marriage, or divorce certificates,
licenses, academic diplomas, academic transcripts, appeals or motions to reopen or
reconsider decisions, explanatory statements, criminal history documents, and unsolicited
information submitted voluntarily by the applicants or family members in support of a
benefit request);

•

Physical description (e.g., height, weight, eye color, hair color, race, ethnicity, identifying
marks like tattoos or birthmarks);

•

Photographs from Government-issued Identification (i.e., passport, Driver’s license, and

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other identification card);
•

Relationships to petitioners, representative, preparers, family members, and applicants;

•

Case processing information such as date applications were filed or received by USCIS,
application/petition status, location of record, other control number when applicable, and
fee receipt data;

•

Organizations associated with applications, petitions or other requests (Place of
business or place of worship, if place of worship is sponsoring the individual);

•

Civil or criminal history information;

•

Uniform resource locators (URLs) 15 or Internet protocol addresses;

•

Biometric identifiers or associated biographic information (e.g., photographic
facial image, fingerprints, Fingerprint Identification Number (FIN), Encounter
Identification Number (EID), and signature);

•

TECS, National Crime Information Center (NCIC), Federal Bureau of
Investigation (FBI) Terrorist Screening Database, and any other data and analysis
resulting from the investigation or routine background identity and security checks
performed in support of the adjudication process; or

•

Any other unique, identifying information.

2.2

What are the sources of the information and how is the information
collected for the project?

Information in FDNS-DS is collected during the following processes: the screening (i.e.,
background, identity, and security check) process, referrals made to FDNS, administrative
investigations, and to conduct studies related to benefit fraud and trends. 16 Much of the information
collected in the FDNS-DS is taken from the benefit request form submitted to USCIS by the
individual or an authorized representative or preparer, or from systems against which that data is
screened during the screening process. USCIS may also collect information through interviews
and site visits and record this into FDNS-DS. Interviewees may include current/past employers,
family members, applicants, or other authorized representatives or preparers.
The information can be collected automatically or manually, as described below.

15

The URL is the unique address for a file that is accessible on the Internet.
See DHS/USCIS/PIA-013-01 FDNS Program, available at www.dhs.gov/privacy, for more information on the
administrative inquiry process, adjudication, and BFA Process. FDNS completes administrative investigations to
obtain relevant information needed to render the appropriate adjudicative decision.
16

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Automatic Collection
FDNS-DS’s event-based screening capability through ATLAS is an automatic collection
process that records certain information for review. Screening within ATLAS is triggered when:
1. An individual presents himself/herself to the agency;
2. Derogatory information is associated with the individual in one or more DHS systems;
or
3. Administrative investigations are performed.
ATLAS queries internal and external systems automatically to obtain data relating to an
individual’s background, identity, and security check. ATLAS receives biographic data (e.g.,
name, date of birth, alias) associated with the individual’s benefit request form from USCIS case
management systems or biographic data associated with the individual’s biometric capture at an
approved biometric collection site (e.g., FIN, A-Number), which may be screened against data in
IDENT, 17 TECS, 18 or the Terrorist Screening Database 19 and then against FDNS-DS’s rules
engine and analytical tools to produce SGNs.
In addition to the automatic collection that occurs during the screening process, FDNS-DS
has a direct connection to the Enterprise Citizenship and Immigration Services Centralized
Operational Repository (eCISCOR) 20 to obtain CLAIMS 21 information about benefit request
forms, applications, or petitions that can be used to automate the population of case information
within FDNS-DS, such as A-Number. This helps to reduce the risk of error from manual data entry
and to preserve the integrity of the information found in source systems.
A comprehensive listing of source systems for this automatic collection is routinely
updated at Appendix A.
Manual Collection
FDNS-DS users may query several DHS databases or systems to obtain information.
Information gathered from these systems (e.g., dates of birth, SSN, country of birth, address) may

17

See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.
18
See DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing (TECS), available at
www.dhs.gov/privacy.
19
See DHS/ALL/PIA-027 DHS Watchlist Service, available at www.dhs.gov/privacy.
20
See DHS/USCIS/PIA-023(a) Enterprise Citizenship and Immigrations Services Centralized Operational
Repository (eCISCOR), available at www.dhs.gov/privacy.
21
See DHS/USCIS/PIA-016(a) CLAIMS 3, available at www.dhs.gov/privacy.

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be added to FDNS-DS. A complete list of DHS systems researched during this process is also
included in Appendix A to this PIA.
Federal, State, and Local Government Sources
FDNS Officers may obtain information from various external sources, such as:
•

Department of Labor;

•

Department of State (DOS);

•

Social Security Administration (SSA) Electronic Verification of Vital Events (EVVE) 22;

•

Federal Aviation Administration websites;

•

Intelligence and law enforcement communities;

•

State and local government agencies;

•

Local, county, and state police information networks;

•

State motor vehicle administration databases and websites;

•

Driver license retrieval websites;

•

State bar associations;

•

State comptrollers;

•

State probation/parole boards or offices;

•

County appraisal districts; and

•

State sexual predator websites.

As described in the FDNS Directorate PIA, FDNS receives information from external partners or
sources during the administrative inquiry process and as part of referrals, requests for assistance,
or requests for information. The type of information collected depends on the specific context of
a given case within FDNS-DS.

2.3

Does the project use information from commercial sources or
publicly available data? If so, explain why and how this
information is used.

FDNS collects information throughout the course of recording, tracking, and managing the
screening and administrative investigation processes related to immigration benefit requests forms,
22

EVVE system allows verification of vital record information from the states, including birth certificates. See
Electronic Verification of Vital Events Program Operations Manual System, available at
https://secure.ssa.gov/poms.nsf, for more information.

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applications, or petitions. FDNS may obtain information from commercial sources or from
publicly available information on the Internet. Examples of commercial or publicly available
sources FDNS may access include, but are not limited to:
•

Commercial data brokers (e.g., Choicepoint AutoTrackXP, Lexis/Nexis Accurint,
Thomson Reuters CLEAR)

•

General legal research sites (e.g., Legal Information Institute)

•

Internet sites such as university websites and newspapers, news media websites,
United Press International, Reuters, and foreign news media websites

•

Various search engines (e.g., Ask, Google, Yahoo, REFDESK)

•

Social media websites (e.g., Facebook, Twitter, LinkedIn, Pinterest, Google+) 23

FDNS-DS enables Officers to note the exact URL and include attachments of any information
collected from commercial sources or publicly available information.
FDNS uses these various commercial and publicly available sources to verify information
provided by the individual, support or refute indications of fraudulent behavior, and identify any
threat to public safety or nexus to known or suspected terrorists in the processing of their benefit
request, consistent with authority granted by the Immigration and Nationality Act. 24 In addition,
the Secretary has delegated USCIS the authority to investigate alleged civil and criminal violations
of the immigration laws, not limited to alleged fraud with respect to applications or
determinations. 25
Compiling this information and taking action to prevent potentially malfeasant and
sometimes dangerous people from staying in this country supports DHS’s mission of preventing
terrorist attacks within the United States and reducing America’s vulnerability to terrorism, while
facilitating the adjudication of lawful benefit applications.

2.4

Discuss how accuracy of the data is ensured.

FDNS-DS relies on the accuracy of the information as it is collected from the source. As
such, the accuracy of the information in FDNS-DS is equivalent to the accuracy of the source
information at the point in time when it is collected into FDNS-DS. During this process, FDNS
conducts data validation to ensure accuracy of the data.

23
FDNS Officers who seek to access, process, store, receive, or transmit PII obtained through the Operational Use
of Social Media while conducting investigations are required to complete a “Rules of Behavior (ROB) for the
Operational Use of Social Media.” These ROBs ensure that users are accountable for their actions on social media,
are properly trained, and aware of the authorized use of social media sites.
24
8 U.S.C. 1101 et seq.
25
See Secretary of Homeland Security Delegation No. 0150.1, Section II (H) and (I), for more information.

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FDNS Officers compare information obtained during the screening and administrative
investigation processes with information provided directly by the individual (applicant or
petitioner) in the underlying benefit request form or in response to Requests for Evidence or
Notices to Appear, to ensure information is matched to the correct individual, as well as to ensure
integrity of the data. As described above, the information contained in benefit request forms,
applications, or petitions may be matched against public records, commercial data aggregators,
and public source information, such as web sites or social media, to validate the veracity of
information provided by the individual.
FDNS uses public source information only as means to verify information already on file
with USCIS or identify possible inconsistencies. Due to the inherent data accuracy risks of relying
on information from the Internet, USCIS requires that no benefit determination action can be taken
based solely on information received from a public source. The information obtained from a public
source must be corroborated with authoritative information on file with USCIS.
In the event FDNS Officers learn that information contained within other systems of
records is not accurate, the Officer will notify appropriate individuals within the USCIS Records
Office or the federal agency owning the data, who will facilitate any necessary notifications and
changes.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk to individual participation because FDNS Officers rely on a
considerable amount of information collected from external sources beyond what individual
submitted on his or her benefit request form.
Mitigation: This risk is partially mitigated. FDNS collects information from a variety of
sources to verify the information provided by individuals in the course of a review of possible
fraud, public safety, and national security concerns. FDNS has determined that in order to have
the best evidence available to support the adjudication process, it is necessary to collect large
amounts of sensitive PII. This information is required to ensure that FDNS makes the correct
determination about the correct individual regarding cases of fraud, criminal activity, public safety,
and national security concerns and sufficiently informs the adjudication of the benefit application.
This risk is also partially mitigated in that individuals have the opportunity to provide information
directly to USCIS throughout the adjudication process and through interviews, Requests for
Evidence, or Notices to Appear.
Privacy Risk: Due to FDNS’s reliance on external sources, including commercial sources,
public sources, or social media, there is a risk that USCIS will obtain and rely upon inaccurate
data.

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Mitigation: The risk is partially mitigated in that FDNS considers information derived
from sources other than the individual, but also exercises caution about the information’s accuracy.
Due to its inherent lack of data integrity, public source information is not used as the sole basis
upon which to adjudicate an immigration benefit or request, investigate benefit fraud, or identify
public safety and national security concerns. FDNS compares historical, biographical, financial,
and personal information presented by the individual against third-party sources, whenever
possible.
In order to improve the accuracy of the information, USCIS has developed policies and
procedures for safeguarding data aggregated within FDNS from several different sources. This
includes using public record data, data from commercial data providers, as well as other publicly
available data including social media and news and reviewing existing data in USCIS’s files with
information outside of USCIS. If inaccurate information is found during the process of reviewing
a file, FDNS will contact personnel within the USCIS Records Division who are authorized to
make the changes to the data in the source system. FDNS will also correct inaccuracies in FDNSDS and other locations where FDNS records are maintained.
Privacy Risk: Because FDNS-DS aggregates information from multiple source systems,
there is a risk of data inaccuracy if the data in the underlying system(s) change.
Mitigation: As noted above, FDNS has policies and procedures in place to confirm the
veracity of the data being relied upon in resolving potential fraud, public safety, and national
security concerns. FDNS-DS also queries other systems in real time to receive the most timely and
accurate data available from the source system. Finally, individuals have opportunities to provide
information directly through the adjudicative process.
Privacy Risk: In some cases, FDNS-DS users enter information into the system manually.
There is a risk of human error, which could result in FDNS relying on inaccurate data.
Mitigation: FDNS has a vested interest and responsibility to maintain the most accurate
data possible since the information could be used in support of an adjudicative decision or in
support of criminal investigations undertaken by law enforcement partners. FDNS Officers rely
on multiple sources to confirm the veracity of the data and, if discrepancies are uncovered, will
take necessary steps to correct inaccuracies.
Privacy Risk: There is a risk that search functions that previously could only have been
performed through separate searches of individual systems or databases will allow FDNS-DS users
(or users of other case management systems that receive data from FDNS-DS) to access to more
data than is necessary to perform their specific roles.
Mitigation: This risk is mitigated in that FDNS-DS maintains strict access controls so that
only FDNS-DS users with a role in investigating cases for potential fraud, public safety, and
national security concerns have access to raw data retrieved as part of the screening process.

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FDNS-DS interfaces with other systems to help streamline the processes that FDNS-DS users
currently perform manually, and its capabilities are designed to assist officers in obtaining
information needed to confirm an individual’s eligibility for the benefit or request sought while
preserving the integrity of the legal immigration system. The output to other case management
systems is reasonably tailored to provide adjudications staff with information relevant to making
a determination on the benefit or request sought.
Privacy Risk: There is a risk of obtaining data from new sources that have not been
reviewed for privacy and legal concerns in determining possible benefit fraud, criminal activity,
public safety, and national security concerns.
Mitigation: The risk is partially mitigated. In order to reduce the risk of new data being
incorporated into FDNS that has not been reviewed for privacy and legal concerns, multiple layers
of privacy and legal review have been built into FDNS’s processes. The process is memorialized
via the Overarching Integrated Project Team (IPT) Charter, which is in the approval process.
Additionally, new sources are reviewed through the FDNS weekly Screening and Case
Management IPTs with participation from the FDNS Privacy Advisor and USCIS Office of
Privacy. FDNS must submit a privacy threshold analysis and receive approval from the DHS
Privacy Office before adding any new data sources.

Section 3.0 Uses of the Information
The following questions require a clear description of the project’s use of information.

3.1

Describe how and why the project uses the information.

FDNS-DS records, tracks, and manages the screening process, thereby increasing the
effectiveness of the U.S. immigration system in combating benefit fraud, protecting public safety,
identifying potential threats to national security, and identifying vulnerabilities that may
compromise the integrity of the legal immigration system.
Screening
FDNS uses FDNS-DS to manage the screening (i.e., background, identity, and security
check) process in support of the adjudication of USCIS benefit requests, in a pre-decisional and
deliberative process. The information can be collected as a part of an automatic collection or
manual collection, as described in Section 2.2.
FDNS uses commercial and publicly available sources, as well as information from other
federal, state, and local government sources, to verify information provided by the
individual/applicant or his/her petitioner or representative, support or refute indications of
fraudulent behavior, and identify any public safety concerns or nexus to known or suspected

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terrorists in the processing of the individual/applicant’s benefit request, pursuant to the
Immigration and Nationality Act. 26
Case Management
FDNS-DS performs case management by recording, tracking, and managing the processes
associated with detecting fraud, egregious or non-egregious public safety, and national security
concerns. FDNS-DS is the central repository for all data gathered during the processes of
performing screening on benefit request forms or applications received, performing administrative
investigations, and conducting studies of benefit fraud rates and trends.
Studies Related to Benefit Fraud and Trends
FDNS uses FDNS-DS data to produce studies related to benefit fraud and trends. 27
Identification of fraud patterns and trends support operational decision management and inform
future rules-based referrals. 28

3.2

Does the project use technology to conduct electronic searches,
queries, or analyses in an electronic database to discover or locate
a predictive pattern or an anomaly? If so, state how DHS plans to
use such results.

Yes. FDNS is incorporating predictive analytics into FDNS-DS to assist in prioritizing the
workload. Predictive technology is applied to known derogatory holdings (e.g., background check
results) in order to categorize information so that the cases most likely to result in a referral for
criminal action are prioritized for the most immediate review. All cases, regardless of their priority,
are reviewed manually by FDNS Officers.

3.3

Are there other components with assigned roles and responsibilities
within the system?

Yes. FDNS-DS information is accessed by or shared with employees or contractors of DHS
components on a need-to-know basis. Limited U.S. Immigration and Customs Enforcement (ICE)
and CBP personnel have been granted read-only access to FDNS-DS. Information sharing includes
tracking interactions with ICE to determine if further law enforcement activities should be pursued.
ICE and CBP must request USCIS permission to share USCIS data with external third parties.

26

8 U.S.C. Section 1101 et seq.
See DHS/USCIS/PIA-013-01 FDNS Program, available at www.dhs.gov/privacy, for more information on the
administrative inquiry process, adjudication, and BFA Process. FDNS completes administrative investigations to
obtain relevant information needed to render the appropriate adjudicative decision.
28
See DHS/USCIS/PIA-055 SAS Predictive Modeling Environment, available at www.dhs.gov/privacy.
27

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At the time of publication of this PIA, FDNS is also working with ICE to establish a
connection to improve the quality and exchange of information with ICE, consistent with the joint
USCIS/ICE anti-fraud strategy discussed in the FDNS Directorate PIA. Through this connection,
FDNS-DS will share information with ICE on cases that may involve egregious public safety
concerns or require further criminal investigation.
Furthermore, at the request of DHS, RFIs for national security purposes from external
entities are coordinated through DHS Office of Intelligence and Analysis (I&A) Single Point of
Service (SPS). 29

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that information contained within the FDNS-DS system is
not used consistently with its original purpose and authority or that individuals may use the data
inappropriately.
Mitigation: Consistent with FDNS’s mission of detecting, deterring, and combating
immigration benefit fraud, all information contained within FDNS-DS is used to identify and track
possible benefit fraud, public safety, and national security concerns. These uses are consistent with
the notice provided to individuals in the Privacy Act Statements on all USCIS forms, as well as
this PIA and the corresponding SORN.
Consistent with USCIS and FDNS governance, user permissions are managed in a stringent
manner to ensure users are only granted the privileges and access necessary to perform their job.
User roles within the application will also be managed in a manner that is reflective of the need
for more restrictive access. Training of users will also incorporate the appropriate use and access
of data.
External users (i.e., CBP and ICE users) are granted read-only access to FDNS-DS only.
USCIS shares FDNS-DS data with ICE, and in some cases with CBP, to determine if further law
enforcement activities should be pursued. ICE and CBP must request USCIS permission to share
USCIS data with external third parties. This ensures sharing is consistent with the routine uses
allowable in the FDNS SORN.
Privacy Risk: There is a risk that SGNs may present FDNS Officers with results that may
contain too many false positives, which may render the resulting data unusable or unreliable or
unfairly subject individuals to further scrutiny.

29

See DHS/ALL/PIA-044 DHS Single Point of Service Request for Information Management Tool, available at
www.dhs.gov/privacy.

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Mitigation: An onboarding phase allows for a period of refining rules before they are
deployed across FDNS. This onboarding phase consists of FDNS-DS users in a limited rollout
receiving rule alerts through e-mail notifications.
USCIS continually tunes the rules to narrow the scope of information provided to FDNS
Officers. Rigorous quality control and assurance procedures are used to adjust rules as necessary
to reduce the potential for false positives. FDNS continually monitors and refines rules based on
appropriate metrics. The SGN process also provides for a layer of human review to confirm SGNs
are actionable prior to routing them for further case management activity.
Privacy Risk: There is a risk of an inappropriate assumption that all individuals listed
within FDNS-DS have engaged in fraudulent immigration-related practices or pose a public safety
or national security risk.
Mitigation: Individuals that are listed within FDNS-DS have potentially engaged in
activities that require further review for potential fraud, criminal activity, public safety, and
national security concerns. However, the existence of a record in FDNS-DS is not in itself
considered derogatory or a reflection on the individual’s eligibility for a benefit, request, or service.
In determinations when potential was not realized, cases are marked with “no fraud found.”
Statements of Findings (SOF) or assessments will contain a summary for adjudication’s use.
Privacy Risk: For certain benefits or service requests, FDNS must share the results of
background, identity, and security checks or other forms of screening with other USCIS case
management systems in order to provide information in support of adjudications. There is a risk
that data will be inaccurately copied or that it may be taken out of context.
Mitigation: The risk is partially mitigated in that FDNS-DS, as a standard practice with
A-File handling, allows the ability to copy a non-changing SOF for adjudications. A SOF is an
unchangeable, PDF document in FDNS-DS. In response to manual referrals made to FDNS-DS,
FDNS users will complete a SOF or assessment, when required. The SOFs or assessments are
shared with adjudications staff. Adjudications staff are trained on how to interpret information in
the SOFs or assessments and their relevance in adjudicating immigration benefits and also
coordinate closely with FDNS.
In future releases, FDNS-DS will interface with USCIS immigration case management
systems to fully automate the screening process, as well as provide the background, identity, and
security check results either in the form of a hit/no hit response, a summary of past screening
history, or some usable form, in order to provide timely, meaningful information to adjudicative
staff. The responses sent to the case management systems will be tailored to present adjudication
officers with information relevant to determining the individual’s eligibility for the immigration
benefit or service sought.

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Privacy Risk: With automating the screening process, there is a risk of recurrent screening
or vetting of individuals beyond the original purpose.
Mitigation: USCIS has established a robust governance structure to ensure that screening
rules are compliant with all legal and privacy requirements. New rules undergo several layers of
operational, legal, privacy, and policy review before they are presented to the Deputy Director,
USCIS, for final approval. Through this process, FDNS ensures that all screening activity is
properly vetted and falls within USCIS’s authority. All screening methods deployed are tailored
to provide information that is relevant to the adjudication of a particular benefit or immigration
service request. USCIS may conduct screening in situations in which USCIS has the authority to
rescind, revoke, or otherwise terminate, to issue a Notice to Appear (NTA), or to refer to another
government agency for criminal/civil actions. When USCIS may no longer take action on a benefit,
service, or request, the screening will cease.
Privacy Risk: There is a risk that FDNS-DS users will create ATLAS rules without going
through the appropriate rules review process.
Mitigation: The governance process ensures that new rules are not created or implemented
within the system without review from the appropriate stakeholders, including privacy and legal
review. Implementation of rules and generation of SGNs are required to be in compliance with the
Privacy Act of 1974, E-Government Act of 2002, Homeland Security Act of 2002 and all DHS
privacy policies. Additionally, the capture, use, and disclosure of PII through the rules process
must be pursuant to applicable system of record notices and available routine uses.

Section 4.0 Notice
The following questions seek information about the project’s notice to the individual about the
information collected, the right to consent to uses of said information, and the right to decline to provide
information.

4.1

How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain why
not.

In addition to the publication of this PIA, USCIS has previously published a programmatic
PIA and SORN for the FDNS Directorate. FDNS-DS collects information from other USCIS
systems, which also have their own PIAs and SORNs published on the DHS website.
All applications for benefits from USCIS have a Privacy Act Statement providing notice
to the individual regarding the use and collection of the information and these forms state the that
information may be used for fraud detection. USCIS forms also notify the individual that

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information provided may be checked for completeness, that certain background checks may be
conducted, or that USCIS may request an interview or further evidence. 30
When FDNS conducts interviews and site visits, FDNS Officers identify themselves and
notify the individual or beneficiary of the reason for the interview or site visit. Notice is given to
an individual’s attorney when an administrative site visit or interview will occur, unless notice
would jeopardize the site visit or interview.

4.2

What opportunities are available for individuals to consent to uses,
decline to provide information, or opt out of the project?

USCIS benefit request forms require that an individual provide specific information that
may contain sensitive PII. The failure to submit such information could impact the processing or
adjudication of an application or petition and thus preclude the individual from receiving the
benefit, request, or service. Therefore, through the application process, individuals have consented
to the use of the information supplied in the benefit request form or application to determine their
eligibility for the benefit, request, or service sought. Further, fraud assessments and background,
identity, and security checks are required by regulation on all requests/applications filed with
USCIS. Benefits, requests, or services cannot be granted until those checks are complete, and the
information submitted is essential to the conduct of those checks. 31
USCIS provides notice to all individuals at the time of collection through a Privacy Act
Statement on all USCIS forms. Individuals are notified at the point of data collection (generally in
the form itself) of the right to decline to provide the required information; however, such action
may result in the denial of the individual’s request.

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk to notice that benefit requestors will not know that FDNS
will collect publicly available information about them, including information posted on public
social media websites and platforms.
Mitigation: The risk has been mitigated to the extent possible because USCIS provides
notice to individuals through an (e)(3) statement, the source system PIAs, the FDNS Directorate
PIA, this PIA, and the associated SORNs. USCIS also provides notice of its fraud detection and
national security work through its public website. 32

30

Adjudicators are responsible for making decisions regarding granting benefits.
As required by Title 8 U.S.C. § 1101 et seq.
32
See https://www.uscis.gov/about-us/directorates-and-program-offices/fraud-detection-and-national-security/frauddetection-and-national-security-directorate.
31

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Section 5.0 Data Retention by the project
The following questions are intended to outline how long the project retains the information after
the initial collection.

5.1

Explain how long and for what reason the information is retained.

USCIS retains application information to assist in identifying individuals who threaten
national security and public safety; detecting, pursuing, and deterring immigration benefit fraud;
and identifying and removing systemic vulnerabilities in the process of the legal immigration
system.
USCIS retains FDNS-DS records for 15 years from the date of the last interaction between
FDNS personnel and the individual, no matter the determination. Records related to a person’s AFile will be transferred to the A-File and maintained under the A-File retention period (N1-56608-11). Upon closure of a case pertaining to an individual, any information that is pertinent to the
adjudicative decision (such as a SOF), whether there was or was not an indication of fraud, criminal
activity, public safety and national security concerns, is transferred to the associated A-File.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk that data will be retained longer than necessary. This would
increase the risk of unauthorized access, use, and loss of the data.
Mitigation: FDNS mitigates this risk by destroying FDNS-DS data in accordance with
approved NARA records retention schedules. The 15-year retention schedule for FDNS data (N1566-08-18) provides access to information that can be critical to research related to suspected or
confirmed fraud, public safety, and national security concerns for individuals who may still be
receiving immigration benefits or services. In addition, should the individual apply for another
benefit, retention of the information can eliminate the need for research on concerns that were
previously addressed.
Privacy Risk: There is a risk that data will be retained in FDNS-DS longer than allowed
by the original source system.
Mitigation: This risk is mitigated in that FDNS-DS retains data relevant to the background
check/screening process and to cases of suspected or confirmed fraud, criminal activity, public
safety and national security concerns. The system’s master 15-year retention period is shorter than
that of many USCIS case management systems from which application data is derived.

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Section 6.0 Information Sharing
The following questions are intended to describe the scope of the project information sharing
external to the Department. External sharing encompasses sharing with other federal, state, and local
government; and private sector entities.

6.1 Is information shared outside of DHS as part of the normal agency
operations? If so, identify the organization(s) and how the information is
accessed and how it is to be used.
FDNS shares information outside of DHS when USCIS receives an RFI, when it
proactively discloses based on information in the record, and when asking an outside organization
for additional information related to an individual. RFIs may be received from federal law
enforcement agencies (e.g., Department of Justice (DOJ) FBI, DOS), the Intelligence Community,
and authorized state or local law enforcement agencies who are parties to information sharing
agreements managed by DHS. USCIS provides access to the requested data through direct user
accounts or through copying of data to an electronic device or medium.
Requests for information are governed by the DHS/USCIS-006 Fraud Detection and
National Security Records (FDNS) System of Records 33, the DHS/USCIS/ICE/CBP-001 Alien
File, Index, and National File Tracking System of Records 34, or in some instances, the originating
system of records notice for the underlying USCIS records, e.g., DHS/USCIS-007 Benefits
Information System (BIS). 35 When covered by an applicable routine use and when appropriate,
USCIS may share the sensitive PII listed in Section 2.1 of this PIA with federal, state, tribal, local,
international, or foreign law enforcement and intelligence agencies, in response to an RFI in
support of criminal and administrative investigations, and background identity and security checks
involving immigrant benefit fraud, criminal activity, public safety, and national security concerns.
Through direct user account access, DOS Bureau of Consular Affairs may view a
comprehensive picture of a visa applicant’s status and to reduce the likelihood that an individual
or group might fraudulently obtain an immigration benefit under the INA, as amended. DOS has
read-only access to FDNS-DS.
Proactive disclosure based on information in the system occurs when FDNS has an
indication of possible fraud, criminal activity, public safety, and national security concerns. In
these cases, FDNS may proactively share information with other government entities as described

33

DHS/USCIS-006 Fraud Detection and National Security Records (FDNS), 77 FR 47411 (Aug. 8, 2012).
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556 (Sept.
18, 2017).
35
DHS/USCIS-007 Benefits Information System 81 FR 72069 (Oct. 19, 2016).
34

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under the FDNS and A-File SORNs. 36
RFIs for national security purposes from external entities are coordinated through DHS
I&A SPS. USCIS responses are provided via government secure networks. All other requests are
processed by USCIS. Responses provided by field offices are also provided via secure methods.

6.2

Describe how the external sharing noted in 6.1 is compatible with
the SORN noted in 1.2.

Direct account access by DOS Bureau of Consular Affairs is covered by FDNS SORN
routine use I and A-File SORN routine use O, which permits USCIS to share PII with DOS Bureau
of Consular Affairs in the processing of applications for benefits. This is compatible with the
original collection under the INA, which requires USCIS to administer immigration laws.
Information may also be shared with DOS Bureau of Consular Affairs to provide a comprehensive
picture of a visa applicant’s status, and to reduce the likelihood that an individual or group might
fraudulently obtain an immigration benefit under the INA, as amended.
Proactive disclosures are covered by the FDNS SORN, routine use H, which permits FDNS
to share PII with federal and foreign government intelligence or counterterrorism agencies when
USCIS reasonably believes there is a threat or potential threat to national or international security.
Proactive disclosures are also covered by routine use H and II of A-File SORN. Routine
use H permits USCIS to share A-File information with appropriate federal, state, tribal, local, or
foreign governmental agencies or multilateral governmental organizations responsible for
investigating or prosecuting the violations of, or for enforcing or implementing, a statute, rule,
regulation, order, or license, when DHS believes the information would assist in enforcing
applicable civil or criminal laws. A-File SORN routine use II permits sharing with a federal, state,
local, territorial, tribal, international, or foreign criminal, civil, or regulatory law enforcement
authority when the information is necessary for collaboration, coordination, and de-confliction of
investigative matters, prosecutions, or other law enforcement actions to avoid duplicative or
disruptive efforts and to ensure the safety of law enforcement officers who may be working on
related law enforcement matters.

36

See DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556
(Sept. 18, 2017); DHS/USCIS-006 Fraud Detection and National Security Records (FDNS), 77 FR 47411 (August
8, 2012).

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These disclosures are compatible with the original collection because the INA requires
USCIS to investigate alleged civil and criminal violations of immigration laws, including alleged
fraud with respect to applications or determinations within USCIS. In addition, the INA provides
for terrorist-related bars that may serve as the basis for denial of a requested benefit. The INA also
requires USCIS to make recommendations for prosecutions or other appropriate actions when
deemed advisable.

6.3

Does the project place limitations on re-dissemination?

Yes. A Memorandum of Agreement (MOA) between USCIS and DOS Bureau of Consular
Affairs fully outlines responsibilities of the parties, security standards, and limits of use of the
information, including re-dissemination. Methods and controls over dissemination of information
are coordinated between USCIS and DOS Bureau of Consular Affairs prior to information sharing.
Depending on the context of other sharing, DHS may place additional controls on the redissemination of the information. FDNS also shares data internally via secure government
networks.
A Memorandum of Understanding (MOU) between DHS and the FBI Terrorist Screening
Center (TSC) for real-time screening against TSDB records also fully outlines responsibilities of
the parties, security standards, and limits of use of the information, including re-dissemination.
A MOA between DHS and the National Counter Terrorism Center also fully outlines
responsibilities of the parties, security standards, and limits of use of the information, including
re-dissemination in accordance with the United States Attorney General Guidelines for Access,
Retention, Use, and Dissemination by the National Counterterrorism Center and Other Agencies
of Information in Datasets Containing Non-Terrorism Information (March 22, 2012).

6.4

Describe how the project maintains a record of any disclosures
outside of the Department.

FDNS maintains a record of disclosure of FDNS-DS information provided outside of the
Department in FDNS-DS. A record is kept on file of each disclosure, and system audit trail logs
are maintained to identify transactions performed by both internal and external users.
As mentioned in the FDNS Directorate PIA, FDNS may receive requests for assistance
from external law enforcement partners. These requests are evaluated on a case-by-case basis, and
disclosures must abide by all privacy laws and legal requirements. Some FDNS Officers are
detailed to partner agencies to provide assistance as immigration subject matter experts. All FDNS
Officers must abide by all privacy laws and legal requirements before sharing any immigration
information. Disclosures made pursuant to these requests for assistance are tracked in FDNS-DS.

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Further, at the request of DHS, Requests for Information for national security purposes
from external entities are coordinated and tracked through the DHS I&A SPS process. 37

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk of misuse, unauthorized access to, or disclosure of,
information.
Mitigation: As discussed above, FDNS maintains a record of each disclosure of FDNS
information made to every agency in accordance with a routine use and with whom it has an
information sharing agreement. Otherwise, FDNS does not share its information. A record is kept
on file of each disclosure, including the date the disclosure was made, the agency to which the
information was provided, the purpose of the disclosure, and a description of the data provided.
The electronic sharing of data with external agencies is conducted over government secure
networks. All personnel within the receiving agency and its components are trained on the
appropriate use and safeguarding of data. In addition, each external agency with whom the
information is shared has policies and procedures in place to ensure there is no unauthorized
dissemination of the information provided by FDNS. Any disclosure must be compatible with the
purpose for which the information was originally collected and only authorized users with a need
to know may have access to the information contained in FDNS-DS.
DHS information is covered by the third-party discovery rule, which precludes agencies
outside of DHS that have received the information from DHS from sharing with additional partners
without the consent of DHS.
Risks are further mitigated by provisions set forth in MOAs or MOUs with federal and
foreign government agencies. Finally, United States government employees and contractors must
undergo annual privacy and security awareness training.

Section 7.0 Redress
The following questions seek information about processes in place for individuals to seek redress
which may include access to records about themselves, ensuring the accuracy of the information collected
about them, or filing complaints.

7.1

What are the procedures that allow individuals to access their
information?

Because FDNS-DS contains sensitive PII related to possible immigration benefit fraud and
37

See DHS/ALL/PIA-044 DHS Single Point of Service Request for Information Management Tool, available at
www.dhs.gov/privacy.

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national security concerns, DHS has exempted FDNS from the notification, access, and
amendment provisions of the Privacy Act of 1974, pursuant to 5 U.S.C. § 552a(k)(2).
Notwithstanding the applicable exemptions, USCIS reviews all such requests on a case-by-case
basis. When such a request is made, and access would not appear to interfere with or adversely
affect the national or homeland security of the U.S. or activities related to any investigatory
material contained within this system, the applicable exemption may be waived at the discretion
of USCIS, and in accordance with procedures and points of contact published in the applicable
SORNs.
Individuals seeking to access information maintained by FDNS should direct their requests
to:
National Records Center
Freedom of Information Act/Privacy Act Program
P. O. Box 648010
Lee’s Summit, MO 64064-8010
Requests for access to records must be in writing. Such requests may be submitted by mail or in
person. If a request for access is made by mail, the envelope and letter must be clearly marked
“Privacy Act Request” to ensure proper and expeditious processing. The requester should provide
his or her full name, date and place of birth, and verification of identity in accordance with DHS
regulations governing Privacy Act requests (found at 6 CFR Part 5.21), and any other identifying
information that may be of assistance in locating the record.
The information requested may, however, be exempt from disclosure under the Privacy
Act because FDNS records, with respect to an individual, may sometimes contain law enforcement
sensitive information. The release of law enforcement sensitive information could possibly
compromise ongoing criminal investigations.
Additional information about Privacy Act and Freedom of Information Act (FOIA)
requests for USCIS records can be found at http://www.uscis.gov.

7.2

What procedures are in place to allow the subject individual to
correct inaccurate or erroneous information?

As stated above, individuals may use the Freedom of Information Act/Privacy Act process
to request access to and correction of records maintained about them. The data accessed by FDNSDS from underlying USCIS source systems may be corrected by means of the processes described
in the PIAs and SORNs for those systems. In the event inaccuracies are noted, files and FDNS-DS
records may be updated.

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7.3

How does the project notify individuals about the procedures for
correcting their information?

Individuals are notified of the procedures for correcting their information on USCIS forms,
the USCIS website, and by USCIS personnel who interact with individuals in the course of
processing requests for benefits or services. Furthermore, this PIA and the respective SORNs serve
as notice to individuals.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that individuals may be able to access, correct, or make
amendments to records in the source systems, but may not be able to do so for their records
maintained in FDNS-DS due to the Privacy Act exemptions claimed.
Mitigation: While FDNS maintains pre-decisional, deliberative information in FDNS-DS,
individuals may still request access to records that USCIS maintains about them. Notice on how
to file a Privacy Act request about records contained in maintained by FDNS is provided by this
PIA and the FDNS SORN. Individuals can request access to information about them through the
Privacy Act and FOIA process, and may also request that their information be amended by
contacting the National Records Center. The nature of FDNS-DS and the data it collects, processes,
and stores is such that it limits the ability of individuals to access or correct their information. Each
request for access or correction is individually evaluated.

Section 8.0 Auditing and Accountability
The following questions are intended to describe technical and policy based safeguards and
security measures.

8.1

How does the project ensure that the information is used in
accordance with stated practices in this PIA?

Access and security controls have been established to mitigate privacy risks associated with
authorized and unauthorized uses, specifically misuse and inappropriate dissemination of data.
Access to FDNS-DS is generally read-only. Some FDNS-DS users have “read,” “write,” and
“modify” privileges. All account access and privileges are approved by the USCIS business owner.
When employment at USCIS is terminated or an employee’s responsibilities no longer require
access to FDNS-DS, access privileges are removed.
Audit trails are kept in order to track and identify unauthorized uses of FDNS-DS
information. The audit trails include the ability to identify specific records each user accesses. A
warning banner is provided at all access points to inform users of the consequences associated with

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unauthorized use of information. The banner warns authorized and unauthorized users about the
appropriate uses of the system, that the system may be monitored for improper use and illicit
activity, and the penalties for inappropriate usage and non-compliance. A user must click on the
agreement to proceed with login.
In addition, user access to FDNS-DS is limited to personnel who need the information to
perform their job functions. Only users with proper permissions, roles, and security attributes are
authorized to access the system. Each user is obligated to sign and adhere to a user access
agreement, which outlines the appropriate rules of behavior tailored for FDNS-DS. The system
administrator is responsible for granting the appropriate level of access. Finally, all employees are
trained on the use of information in accordance with DHS policies, procedures, regulations, and
guidance.
FDNS conducts continuous security assessments of FDNS-DS in accordance with FISMA
requirements. Furthermore, FDNS-DS complies with the DHS 4300A security guidelines, which
provide hardening criteria for securing networks, computers, and computer services against attack
and unauthorized information dissemination. Additionally, FDNS is subject to random Office of
Inspector General (OIG) or any DHS assigned third-party security audits.

8.2

Describe what privacy training is provided to users either generally
or specifically relevant to the project.

FDNS-DS users receive the required annual Computer Security Awareness training and
Privacy Act Awareness training. In addition, users receive training in the use of FDNS-DS prior
to being approved for access to the system. The training addresses the use of the system and
appropriate privacy concerns, including Privacy Act obligations (e.g., SORNs, Privacy Act
Statements). FDNS Officers also have several mandatory, job-specific training requirements that
include discussions on Privacy Act obligations and other restrictions on disclosure of information.

8.3

What procedures are in place to determine which users may access
the information and how does the project determine who has
access?

Users receive access to FDNS-DS only on a need-to-know basis. This need-to-know is
determined by the individual’s current job functions. Users may have read-only access to the
information if they have a legitimate need to know as verified by their supervisor and the FDNSDS business owner, and have successfully completed all required training.
A user requesting access must complete and submit Forms G-872A and B, USCIS and End
User Application for Access. This application provides the justification for the level of access
requested. Additionally the requestor signs the USCIS Rules of Behavior before access is granted.

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The requestor’s supervisor and the FDNS-DS business owner will review this request; if approved,
the requestor’s access level is independently confirmed and the user account established.
Criteria, procedures, controls, and responsibilities regarding FDNS-DS systems access are
contained in the Sensitive System Security plan for FDNS-DS. Additionally, there are several
department and government-wide regulations and directives that provide additional guidance and
direction

8.4 How does the project review and approve information sharing
agreements, MOUs, new uses of the information, new access to the system by
organizations within DHS and outside?
MOAs and MOUs between USCIS and other components of DHS, as well as MOAs and
MOUs between USCIS or DHS and other agencies, define information sharing procedures for data
maintained by FDNS. MOAs and MOUs document the requesting agency or component’s legal
authority to acquire such information, as well as USCIS’s permission to share in its use under the
legal authority granted. All MOAs and MOUs must be reviewed by the program and all applicable
parties.

Responsible Officials
Donald K. Hawkins
U.S. Citizenship and Immigration Service
Privacy Officer
Department of Homeland Security

Approval Signature

Original, signed copy on file with the DHS Privacy Office.
________________________________
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security

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APPENDIX A
List of Systems of Records Researched during the Screening Processes and
Tracked in FDNS-DS
Below is a list of systems, both internal and external, that exchange data with FDNS-DS, including
those used to support screening through ATLAS.
U.S. Citizenship and Immigration Services (USCIS) Systems
•

National Benefit Center Process Workflow Repository (NPWR) 38 to facilitate screening
on certain form types being processed through the National Benefit Center, Background
Check Unit;
ATLAS is the conduit to perform TECS (SQ-11 and NCIC) checks and return those results
to NPWR. ATLAS also receives information from biographic-based checks and performs
screening to produce system generated notifications (SGNs).
o PIA:
o Computer Linked Application Information Management System
(CLAIMS 3) 39
o Computer Linked Application Information Management System 4
(CLAIMS 4) 40
o Refugees, Asylum, and Parole System (RAPS) and the Asylum PreScreening System (APSS) 41
o Case and Activity Management for International Operations
(CAMINO) 42
o USCIS Electronic Immigration System (USCIS ELIS) 43
o SORN:
o A-File, Index, and National File Tracking System 44
o Fraud Detection and National Security Records (FDNS) 45

38

NPWR is covered under DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems.
See DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems, available at www.dhs.gov/privacy.
40
See DHS/USCIS/PIA-015 CLAIMS 4 and subsequent updates, available at www.dhs.gov/privacy.
41
See DHS/USCIS/PIA-027 RAPS/APSS and subsequent updates, available at www.dhs.gov/privacy.
42
See DHS/USCIS/PIA-051 CAMINO, available at www.dhs.gov/privacy.
43
See DHS/USCIS/PIA-056 USCIS ELIS, available at www.dhs.gov/privacy.
44
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556 (Sept.
18, 2017).
45
DHS/USCIS-006 Fraud Detection and National Security Records (FDNS), 77 FR 47411 (Aug. 8, 2012).
39

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o Forthcoming Immigration Biometric and Background Check
System
o Benefits Information System (BIS) 46
o Intercountry Adoptions Security47
•

Service Center Computer Linked Application Information Management System
(SCCLAIMS) 48 to facilitate screening on forms processed in other USCIS case
management systems;
SCCLAIMS maintains a mirror copy of CLAIMS 3 data and is screened against rather than
CLAIMS 3 for efficiency purposes. SCCLAIMS is an FDNS system, receives a daily
refresh of CLAIMS 3 data, and maintains the CLAIMS 3 data elements needed to perform
screening of those benefit request forms processed in CLAIMS 3.
SCCLAIMS is also used by FDNS-DS/ATLAS to maintain records related to background,
identity, and security checks performed through ATLAS’s screening capabilities and the
corresponding data from its screening algorithms. The types of data will depend on the type
of checks performed.
o PIAs:
o FDNS Directorate 49
o FDNS-Data System (FDNS-DS)
o CLAIMS 3 50
o SORNs:
o Fraud Detection and National Security Records 51
o A-File, Index, and National File Tracking System 52
o Forthcoming Immigration Biometric and Background Check
System

46

DHS/USCIS-007 Benefits Information System, 81 FR 72069 (Oct. 19, 2016).
DHS/USCIS-005 Inter-Country Adoptions Security, 81 FR 78614 (Nov. 8, 2016).
48
SCCLAIMS is a mirror copy of CLAIMS 3 data.
49
See DHS/USCIS/PIA-013-01 Fraud Detection and National Security (FDNS) Directorate, available at
www.dhs.gov/privacy.
50
See DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems, available at www.dhs.gov/privacy.
51
DHS/USCIS-006 Fraud Detection and National Security Records (FDNS), 77 FR 47411 (Aug. 8, 2012).
52
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556 (Sept.
18, 2017).
47

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•

CLAIMS 3;
(U//FOUO) Through an automated connection to SCCLAIMS, ATLAS receives
information from both biographic and biometric-based checks and performs screening to
produce SGNs.
o PIAs: CLAIMS 3 53
o SORN: BIS 54

•

CLAIMS 4;
At present, ATLAS receives information from both biographic and biometric-based checks
and performs screening to produce SGNs. ATLAS does not connect directly to or return
information to CLAIMS 4.
o PIA: CLAIMS 4 55
o SORN: BIS 56

•

USCIS ELIS;
At present, ATLAS receives information from both biographic and biometric-based checks
and performs screening to produce SGNs.
FDNS is developing further options for invoking ATLAS’s screening capability as
described in this PIA in order to return a response to ELIS.
o PIA: ELIS 57
o SORN: BIS 58

•

CAMINO;
At present, ATLAS receives information from biometric-based checks and performs
screening to produce SGNs. ATLAS does not return information to CAMINO.
o PIA: CAMINO 59
o SORN:
o A-File, Index, and National File Tracking System 60

53

See DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems, available at www.dhs.gov/privacy.
DHS/USCIS-007 Benefits Information System, 81 FR 72069 (Oct. 19, 2016).
55
See DHS/USCIS/PIA-015 CLAIMS 4 and subsequent updates, available at www.dhs.gov/privacy.
56
DHS/USCIS-007 Benefits Information System, 81 FR 72069 (Oct. 19, 2016).
57
See DHS/USCIS/PIA-056 USCIS ELIS, available at www.dhs.gov/privacy.
58
DHS/USCIS-007 Benefits Information System, 81 FR 72069 (Oct. 19, 2016).
59
See DHS/USCIS/PIA-051 CAMINO, available at www.dhs.gov/privacy.
60
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556 (Sept.
54

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o Forthcoming Immigration Biometric and Background Check
System
o Intercountry Adoptions Security61
o BIS
o Asylum Information and Pre-Screening (AIPS) 62
•

RAPS/APSS; 63
At present, ATLAS receives information from biometric-based checks and performs
screening to produce SGNs. ATLAS does not connect directly to or return information to
RAPS/APSS.
o PIA: RAPS/APSS 64
o SORN: AIPS 65

•

Marriage Fraud Assurance System (MFAS);
At present, ATLAS receives information from biometric-based checks and performs
screening to produce SGNs. ATLAS does not connect directly to or return information to
MFAS.
o PIA: CLAIMS 3 66
o SORN:
o A-File, Index, and National File Tracking System
o Forthcoming Immigration Biometric and Background Check
System
o BIS

•

Adoption Case Management System (ACMS);
At present, ATLAS receives information from biometric-based checks and performs
screening to produce SGNs. ATLAS does not connect directly to or return information to
ACMS.

18, 2017).
61
DHS/USCIS-005 Inter-Country Adoptions Security, 81 FR 78614 (Nov. 8, 2016).
62
DHS/USCIS-010 AIPS, 80 FR 74781 (November 30, 2015).
63
See DHS/USCIS/PIA-027 RAPS/APSS, and subsequent updates, available at www.dhs.gov/privacy.
64
See DHS/USCIS/PIA-027 RAPS/APSS, and subsequent updates, available at www.dhs.gov/privacy.
65
DHS/USCIS-010 AIPS, 80 FR 74781 (November 30, 2015).
66
See DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems, available at www.dhs.gov/privacy.

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o PIA: Domestically Filed Intercountry Adoptions Applications and
Petitions 67
o SORN: Intercountry Adoptions Security68
•

USCIS Lockbox 69 to retrieve data from digitized forms;
o PIA: Benefit Request Intake Process 70
o SORN:
o A-File, Index, and National File Tracking System
o Forthcoming Immigration Biometric and Background Check
System BIS
o Intercountry Adoptions Security
o AIPS 71
o Collections Records--Treasury/Financial Management Service 72

•

Person Centric Query Service (PCQS) to retrieve status information from the Central Index
System (CIS);
o PIA: PCQS 73
o SORN: See PCQS PIA Appendices for associated SORNs

•

National File Tracking System (NFTS) to retrieve the physical locations of A-Files;
o PIA: NFTS 74
o SORN: A-File, Index, and National File Tracking System

•

Customer Profile Management System (CPMS) to retrieve data associated with biographic
and biometric screening.
o PIA: CPMS 75

67

See DHS/USCIS/PIA-003(a) Integrated Digitization Document Management Program (IDDMP), available at
www.dhs.gov/privacy.
68
DHS/USCIS-005 Inter-Country Adoptions Security, 81 FR 78614 (Nov. 8, 2016).
69
See DHS/USCIS/PIA-007(b) Domestically Filed Intercountry Adoptions Applications and Petitions, available at
www.dhs.gov/privacy.
70
See DHS/USCIS/PIA-061 Benefit Request Intake Process, available at www.dhs.gov/privacy.
71
DHS/USCIS-010 AIPS, 80 FR 74781 (November 30, 2015).
72
Treasury/FMS.017 - Revenue Collections Records, 74 FR 23006 (May 15, 2009).
73
See DHS/USCIS/PIA-010 Person Centric Query Service (PCQS), available at www.dhs.gov/privacy.
74
See DHS/USCIS/PIA-032 National File Tracking System (NFTS), available at www.dhs.gov/privacy.
75
See DHS/USCIS/PIA-060 Customer Profile Management Service, available at www.dhs.gov/privacy.

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o SORN: Forthcoming Immigration Biometric and Background Check
System
Other Department of Homeland Security (DHS) Component System Interfaces
•

DHS Automated Biometric Identification System (IDENT) to retrieve data associated with
biometric screening;
o PIA: IDENT 76
o SORN: IDENT 77

•

U.S. Customs and Border Protection (CBP) TECS system, to perform screening, including
checks against the Federal Bureau of Investigation, National Crime Information Center
(NCIC);
o PIA: TECS 78
o SORN: CBP TECS 79

•

CBP Automated Targeting System-Passenger (ATS-P) to support vetting against
Intelligence Community and Law Enforcement holdings for certain benefit types;
ATLAS sends immigration request/application data to ATS to be recurrently vetted against
law enforcement (and in the future, intelligence) holdings; ATLAS sends real-time
adjudication status updates to ATS to indicate when recurrent vetting should cease. This
effort is fully documented in Appendix D to this PIA.
o PIA: ATS-P 80
o SORN: ATS 81

•

DHS Watchlist Service for real-time screening against Terrorist Screening Data Base
(TSDB) records; and
o PIA: FDNS WLS PIA Update 82
o SORN: DHS WLS SORN 83

76

See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.
77
DHS/USVISIT-004 DHS Automated Biometric Identification System (IDENT) 72 FR 31080 (June 5, 2007).
78
See DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing, available at
www.dhs.gov/privacy.
79
DHS/CBP-011 U.S. Customs and Border Protection TECS 73 FR 77778 (Dec. 19, 2008).
80
See DHS/CBP/PIA-006(b) Automated Targeting System (ATS), available at www.dhs.gov/privacy.
81
DHS/CBP-006 Automated Targeting System, 77 FR 30297 (May 22, 2012).
82
See DHS/USCIS/PIA-027(e) DHS Watchlist Service, available at www.dhs.gov/privacy.
83
DHS/ALL-030 Use of the Terrorist Screening Database System of Records, 81 FR 19988 (April 6, 2016).

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•

DHS Email as a Service (EaaS) Simple Mail Transfer Protocol (SMTP) server for email.
o PIA: E-mail Secure Gateway 84
o SORN:
o General Information Technology Access Account Records System
(GITAARS) 85
o General Personnel Records 86

Other DHS Component Systems Accessed (Manually)
•

CBP Analytical Framework for Intelligence (AFI)
o PIA: AFI 87
o SORN: AFI for Intelligence System 88

•

CBP Arrival and Departure Information System (ADIS)
o PIA: ADIS 89
o SORN: ADIS 90

•

ICE Student and Exchange Visitor Information System II (SEVIS)
o PIA: SEVIS II 91
o SORN: SEVIS 92

•

ICE ENFORCE Alien Removal Module
o PIA: Enforcement Integrated Database (EID) 93
o SORN: Criminal Arrest Records and Immigration Enforcement Records
(CARIER) 94

84

See DHS/ALL/PIA-012 E-mail Secure Gateway and subsequent updates, available at www.dhs.gov/privacy.
DHS/ALL-004 General Information Technology Access Account Records System (GITAARS), 77 FR 70792
(November 27, 2012).
86
OPM/GOVT-1 General Personnel Records 77 FR 73694 (December 11, 2012).
87
See DHS/CBP/PIA-010 AFI, available at www.dhs.gov/privacy.
88
DHS/CBP-017 Analytical Framework for Intelligence System, 77 FR 13813 (June 7, 2012).
89
See DHS/CBP/PIA-24 Arrival and Departure System (ADIS), available at www.dhs.gov/privacy.
90
DHS/CBP-021 Arrival and Departure Information System (ADIS), 80 FR 72081 (November 18, 2015).
91
See DHS/ICE/PIA-001(a) Student and Exchange Visitor Information System II (SEVIS), available at
www.dhs.gov/privacy.
92
DHS/ICE 001 Student and Exchange Visitor Information System, 75 FR 412 (January 5, 2010).
93
See DHS/ICE/PIA-015 Enforcement Integrated Database (EID) and subsequent updates, available at
www.dhs.gov/privacy.
94
DHS/ICE-011 CARIER System of Records, 81 FR 72080 (Oct. 19, 2016).
85

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APPENDIX D
Continuous Immigration Vetting
Summary
The U.S. Citizenship and Immigration Services (USCIS) Fraud Detection and National
Security (FDNS) is working with the U.S. Customs and Border Protection (CBP) National
Targeting Center (NTC) and Targeting and Analysis Systems Program Directorate (TASPD) to
enhance and streamline background, identity, and security checks for certain USCIS benefit types
through an interagency effort: continuous immigration vetting (CIV). CIV is an end-to-end
solution that makes use of existing connections between USCIS and CBP, which are currently
used in the refugee vetting process 95, to recurrently vet immigration service and benefit requests
against relevant law enforcement and intelligence partner holdings. CIV screens individuals who
have applied for a USCIS immigration benefit/request recurrently throughout the adjudication
process, resulting in real-time notification of information that could potentially impact the
adjudication.
This process uses a connection between USCIS Fraud Detection and National Security –
Data System (FDNS-DS)/ATLAS and CBP Automated Targeting System (ATS) to automate
certain checks that would otherwise be performed manually and to serve as a new data feed to the
ATLAS rules/event-based referral process discussed in the body of this PIA 96.
ATLAS makes use of information already obtained through existing interfaces 97 with
USCIS and DHS immigration case management and screening systems, such as USCIS ELIS 98
and DHS IDENT 99, to transmit biographic data from or associated with immigration benefit filings
to CBP ATS for recurrent vetting. It is through these interfaces that ATLAS can also receive realtime adjudication status updates and provide notification to CBP ATS when recurring vetting
should stop.
USCIS/CBP are implementing CIV in a phased approach, beginning with conducting
security checks on applications or requests filed with USCIS against data available in ATS and
eventually expanding to encompass checks for benefit and identity fraud, criminal/public safety
issues, and, where appropriate, security checks against interagency or intelligence community
95

See DHS/USCIS/PIA-068 Refugee Case Processing and Security Vetting and DHS/CBP/PIA-006(3) ATS,
available at www.dhs.gov/privacy.
96
Information about form intake and initial screening is also included in the various PIAs for the USCIS case
management systems and background check systems that make up a part of this process (e.g., CLAIMS 4, ELIS,
CPMS).
97
See DHS/USCIS/PIA-013(a) Fraud Detection and National Security Data System (FDNS-DS) Appendix A,
available at www.dhs.gov/privacy for a complete list of system interfaces to FDNS-DS/ATLAS.
98
See DHS/USCIS/PIA-056 ELIS, available at www.dhs.gov/privacy.
99
See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.

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holdings. Throughout this implementation, USCIS and CBP will continue to assess the legal,
privacy, and policy implications and to define rules for recurrent vetting.
In future phases of CIV, USCIS and CBP will work with external partners to develop a
solution that perform security checks for certain immigration benefits. USCIS will update this PIA
to account for any expansion of CIV.
Core Capabilities Supported
ATLAS Intelligent Investigative Case Management, Operational Decision Management,
Information Sharing and Collaboration.
Characterization of the Information
ATLAS sends to CBP ATS information derived from immigration applications filed with
USCIS or from the submission of biometrics, to include the same data elements currently used
today when ATLAS conducts event-based background, identity, and security checks. This
includes, but is not limited to:
•

Unique Subject ID;

•

Receipt number;

•

Applicant name (First, Middle, Last);

•

Date of birth;

•

Gender;

•

Country of birth;

•

Citizenship;

•

Country of residence;

•

Current/Class of admission;

•

Alien Registration number;

•

Social Security number;

•

I-94 number;

•

Passport information;

•

Address;

•

Foreign address;

•

Telephone number;

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•

Ethnicity;

•

Sex;

•

Height;

•

Weight;

•

Email;

•

Adjudication status;

•

Fingerprint Identification Number;

•

Encounter ID; and

•

Organization/Unit/Sub-Unit Code.

Data Use and Retention
As described in the body of this PIA and in Appendix A, ATLAS queries both internal and
external systems automatically to obtain data relating to an individual’s background, identity, and
security risk. CIV will make use of existing connections between USCIS and CBP, which are
currently used in the refugee vetting process 100, to recurrently vet immigration service and benefit
requests against law enforcement and intelligence partner holdings throughout the adjudication
process.
ATLAS will receive vetting results returned from CBP ATS (and in the future, will receive
vetting results from interagency partners). ATLAS filters these results through its rules engine and
then transmits the completed results to the end-user in the form of a system generated notification
(or SGN). As discussed in the existing FDNS-DS/ATLAS PIA, the approved rules standardize
how information is analyzed and filter the results so that only information that assists in the
identification of potential benefit or identity fraud, public safety issues, or national security
concerns (or trends) is returned. Specially trained FDNS officers serve as gatekeepers who conduct
manual reviews of SGNs for validity and to determine if the referral is actionable before it enters
the FDNS-DS investigative case management work stream. ATLAS is also able to consolidate
information received from multiple sources (e.g., a TECS check vs. an ATS check) to avoid
sending duplicate SGNs.
CBP ATS retains USCIS records and vetting results for the duration of CIV in order to
assist USCIS in conducting recurrent vetting on immigration filings. This process ultimately
supports adjudication of requests for immigration benefits pursuant to USCIS’s authority under

100

See DHS/USCIS/PIA-068 Refugee Case Processing and Security Vetting and DHS/CBP/PIA-006(3) ATS,
available at www.dhs.gov/privacy.

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the Immigration and Nationality Act.
ATLAS provides ATS with real-time adjudication status updates to inform CBP when
recurrent vetting should stop. ATS stops recurrent vetting for ATLAS when encountering
administrative closure from an Immigration Judge's calendar or from the Board of Immigration
Appeal's docket, certificate of citizenship issue, denial, failure to pay, or withdrawn adjudication
activities. Upon such notification, CBP must purge the records from ATS unless that information
is linked to active law enforcement lookout records, enforcement activities, or investigations in
which case the data will be maintained by CBP in ATS consistent with the ATS retention schedule,
as reflected in the ATS system of records notice.
Results:
FDNS will use the CBP vetting results to augment the existing ATLAS rules-based referral
process used to produce SGNs based on fraud, public safety, and national security concerns. This
process will result in increased efficiencies in the background, identity, and security check process
through receipt of real-time notifications of information that may impact adjudications.
Privacy Risks/Mitigation:
Privacy Risk: There is a risk that recurrent vetting will continue after the adjudication of
an immigration benefit.
Mitigation: To mitigate this risk, ATLAS has been configured to receive real-time
adjudication status updates and will deliver those updates to CBP ATS as notification of when
vetting should stop. CBP will be required to return an acknowledgment of receipt of such
notification as well as a real-time stopped recurrent vetting indicator. CBP will not retain this data
in ATS post-adjudication unless that information is linked to active law enforcement lookout
records, enforcement activities, or investigations or cases, in which case that data is maintained by
CBP in ATS consistent with the ATS retention schedule as reflected in the ATS SORN (i.e., for
the life of the law enforcement matter to support that activity and other enforcement activities that
may become related).
Privacy Risk: Under CIV, USCIS will send a greater volume of data elements to CBP than
CBP would otherwise receive when encountering individuals as part of its border crossing mission
thereby creating a risk of over-collection of information in ATS.
Mitigation: USCIS has determined this volume of information is necessary to ensure the
fidelity of the ATLAS/ATS joint screening and matching capabilities. Further, retaining this data
in CBP ATS throughout the adjudicative process is necessary to enhance vetting capabilities in the
event an individual presents themselves to DHS again, either through travel or in connection with
immigration applications, petitions, or requests. The requirement to purge the data from ATS postadjudication mitigates the risk of over-collection and any potential misuse of information. CBP

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will only access the data elements in these files if they are linked to a law enforcement or national
security concern.
Privacy Risk: Because ATLAS also performs TECS checks on individuals at various
points during the adjudication process, there is a risk that adding ATS as a source for law
enforcement information may produce duplicate SGNs.
Mitigation: To mitigate this risk, ATLAS has been developed with the capability to
consolidate information received from multiple sources and to suppress duplicate SGNs so that
the end user in FDNS-DS is not presented with duplicate sets of the same information. Instead, the
end-user will be notified of new or changed information, such as the receipt of new derogatory
information related to an individual/subject.
Privacy Risk: Lastly, there is a risk that insufficient notice has been provided so that
individuals understand they will be subject to recurrent vetting up through the point of adjudication
of a benefit.
Mitigation: This risk is mitigated in that the results under CIV will be filtered through the
existing rules-based referral process outlined in the body of this PIA. Through this PIA, USCIS
has provided notice that the following events trigger rules-based referrals and SGNs:
1) when an individual presents him or herself to the agency (e.g., when USCIS receives an
individual’s benefit request form 101 or while capturing an individual’s 10-fingerprints at an
authorized biometric capture site, for those forms that require fingerprint checks);
2) when derogatory information is associated with the individual in one or more DHS
systems (i.e., ATS); and
3) when FDNS performs an administrative inquiry or investigation.
USCIS has also updated Appendix A of this PIA to reflect the automated connection to ATS so
that individuals are aware that ATS is a new data source added to the existing event-based referral
process. USCIS’s use of the information remains unchanged from the original PIA. Separately,
CBP is reviewing its compliance documents to determine appropriate updates for added
transparency.

101

See DHS/USCIS/PIA-061 Benefit Request Intake Process, available at www.dhs.gov/privacy.