Forms/PTA

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

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
PIA@hq.dhs.gov
Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.

Privacy Threshold Analysis – IC/Form

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

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

ICE Form I-352

Form Title:
Component:

Immigration Bond
Immigration and
Customs Enforcement
(ICE)

Office:

Enforcement and
Removal Operations
(ERO)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Immigration Bond
December 31, 2019
OMB Control
OMB No. 1653-0022
OMB Expiration
Number:
Date:
Collection status:
Revision
Date of last PTA (if
September 19,
applicable):
2017

Name:
Office:

Phone:

PROJECT OR PROGRAM MANAGER
Christopher D. Florian
Commercial &
Title:
Associate Legal Advisor
Administrative Law
Division (CALD), Office of
the Principal Legal Advisor
(OPLA
(802) 288-7685
Email:
Christopher.D.Florian@ice.d
hs.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT

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

Name:
Office:
Phone:

Scott Elmore
ICE OCIO
Title:
ICE Forms Manager
(202) 732-2601
Email:
Scott.A.Elmore@ice.dhs.gov
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
The data collected on Form I-352 “Immigration Bond” is being updated to allow ERO to
accept Maintenance of Status and Departure (MS&D) bonds. Because non-immigrants
required to post MS&D bonds do not have A-Numbers, the revised form will collect the
visa number instead of the Alien Registration Number (A-Number) for MS&D bonds. No
other personally identifiable information (PII) changes will be made to this form.
An immigration bond is posted as security for performance and fulfillment of the bonded
alien’s obligations to the Government. The data collected on Form I-352 “Immigration
Bond” is used by ICE to ensure that the person or company posting the bond is aware of
the duties and responsibilities associated with the bond. By completing this form, the
bond obligor (either an individual or a surety company) provides a formal, written
guarantee as security for the amount of the bond, thereby assuring DHS that all of the
conditions of the bond will be fulfilled.
This form collects information about the bond obligor, the alien for whom the bond is
furnished, DHS employees, and individuals who pledge bonds, notes, or cash. The
complete list of data elements collected on this form can be found in the answer to
Question 2e (below). Members of the public (i.e., bond obligors) complete and sign Form
I-352 in person at a local ERO field office. Surety agents log into the electronic Bonds
Online System (eBONDS) to complete and submit the I-352 to ERO.

b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

The Immigration and Nationality Act, as amended, (8 U.S.C. 1103, 1183, 1226, 1229c, and
1363) authorizes the collection of information on this form. The Internal Revenue Code
(26 U.S.C. 6109) and Executive Order 9397 authorize the collection of the Social Security
number (SSN). 8 U.S.C. 1103 and 1360 authorize collection of the Alien Registration
Number (A-number), or Visa Number.

2. Describe the IC/Form
a. Does this form collect
any Personally
Identifiable Information”
(PII1)?
b. From which type(s) of
individuals does this
form collect information?
(Check all that apply.)

c. Who will complete and
submit this form? (Check
all that apply.)

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.
☒ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.
☒ The record subject of the form (e.g., the
individual applicant).
☒ Legal Representative (preparer, attorney, etc.).
☒ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☒ No
☐ Law enforcement.
☒ DHS employee or contractor.

1

Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
Names and signatures of individuals who pledge
bonds, notes, or cash.
d. How do individuals
complete the form? Check
all that apply.

☒ Paper.
☒ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via
the internet)
Provide link:
https://ebonds.ice.gov/ebonds/welcome.do

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
Information about the obligor:
Name, physical address, phone number, signature, power of attorney number, and
Taxpayer Identification Number (TIN). If the obligor is a sole proprietor, the TIN might
be an individual’s SSN. For cash bonds, the obligor’s SSN is collected to pay interest
through the U.S. Treasury Department and to comply with Internal Revenue Service
requirements to report interest payments.
Information about the surety agent:
Name of Agent, physical address, telephone number, power of attorney number.
Information about the surety company:
Company name, physical address, phone number, TIN. If the surety company is a sole
proprietor, the TIN might be an individual’s SSN.
Information about the alien for whom the bond is posted:
Name, alien registration number (A-number) or Visa number, bond receipt number,
current location, date and country of birth, nationality, date, port and means of arrival in
the United States, address where alien is to reside, and telephone number at alien's
residence.
Information about DHS employee:
Field Office Director Name and signature.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☒ Alien Number (A-Number)
☐ Social Media Handle/ID
☒ Tax Identification Number
☐ Known Traveler Number
☒ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:
g. List the specific authority to collect SSN or these other SPII elements.
The Internal Revenue Code (26 U.S.C. 6109) and Executive Order 9397 authorizes the
collection of the SSN. 31 U.S.C. 7701(c)(1) authorizes the collection of the TIN. 8 U.S.C.
1103 and 1360 authorize collection of the Alien Registration Number (A-number) or Visa
Number.

h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
For cash bonds, the obligor’s SSN is necessary to pay interest through the U.S. Treasury
Department and to comply with Internal Revenue Service requirements to report
interest payments. The obligor’s, surety agent’s, or surety company’s SSN (in the case of a
sole proprietor) or TIN will also be used for the purposes of collecting and reporting
information on any delinquent accounts arising out of the individual’s relationship with
the Government.
ICE must collect the A-number as a means to properly identify the alien for whom the
bond is being posted. ICE will not have A-Numbers for nonimmigrants who post MS&D

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

bonds. Therefore, ICE will be collecting the visa number from aliens who will be
required to post MS&D bonds.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at
Click here to enter text.
the time of collection
☐ No.
by DHS (Does the
Bond obligors and surety agents have notice of the
records subject have
collection because they are the individuals supplying
notice of the
the information on the form.
collection or is form
filled out by third
Additionally, notice is provided by the privacy notice
party)?
that is on the form, and by the following ICE privacy
compliance documentation:
ICE PIAs
•

DHS/ICE/PIA-005(a) Bond Management
Information System 2009

•

DHS/ICE/PIA-005 Bond Management
Information System 2008

•

DHS/ICE-PIA-015(b) Enforcement Integrated
Database (EID) ENFORCE Alien Removal
Module (EARM 3.0)

•

DHS/ICE/PIA-008 eBonds Online System

ICE SORNs
•

DHS/USCIS/ICE/CBP-001 - Alien File, Index,
and National File Tracking System of Records
(A-FILE SORN)

•

DHS/ICE-004 Bond Management Information
System of Records Notice (SORN)

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

•

DHS / ICE 011 – Criminal Arrest Records and
Immigration Enforcement Records (CARIER)

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
Forms are stored electronically in the ENFORCE
Allen Removal Module (EARM), Bond
Management Information System – Web (BMIS
Web), eBONDS, and the eBONDS SharePoint
document repository.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Forms are not scanned
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
Same data elements noted in Question No. 2(e)
☒ Automatically. Please describe.
Two system-to-system interfaces provide data to
EID in support of the electronic processing of
immigration bonds. The first is an interface with
ICE’s Electronic Bond Online System (eBONDS)
and the second is with ICE’s Bond Management
Information System/Web Version (BMIS Web).

c. How would a user
search the
information
submitted on the

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.

2

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

forms, i.e., how is the
information
retrieved?

A-number, or Visa Number; Name, and bond
receipt number
☐ By a non-personal identifier. Please describe.
Click here to enter text.
Form I-352 falls under Records Retention Schedule
N1-566-08-11, which covers Alien Files. These files
are kept permanently after transfer to the National
Archives and Records Administration (NARA).

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
The ERO Bond Management Unit (BMU) takes
that records are
mandatory ICE Records Training and follows ICE
disposed of or deleted
Records Guidance ensuring that I-352 forms are
in accordance with
disposed of in accordance with the applicable
the retention
retention schedules.
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☒ Yes, information is shared with other DHS components or offices. Please describe.
This information will be used by and disclosed to U.S. Citizenship and Immigration
Services and U.S. Customs and Border Protection or to other DHS personnel and
contractors who need the information to support the enforcement of immigration
laws and the provision of immigration benefits.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
DHS may share this information with the U.S. Treasury Department to report
interest paid to an obligor, and to facilitate payments to or collection of monies owed
by an obligor. DHS may also share this information with the U.S. Justice Department
and other Federal and State agencies for collection, enforcement, investigatory, or
litigation purposes, or as otherwise authorized pursuant to the relevant System of
Records Notice (SORN).
For MS&D bonds, DHS may share information about the posting of a bond on behalf of a
non-immigrant with the Department of State so that the Department of State can
complete issuance of a visa to the non-immigrant.

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

☐ No. Information on this form is not shared outside of the collecting office.

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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

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

Kevin Mullinix

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

August 12, 2019

Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

August 14, 2019
☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
This updated ICE Form 352, Immigration Bond PTA is being submitted for review. Because
this form collects information from the surety agent, or company on behalf of the bonded
alien, a Privacy Act notice is required. ICE Form 352, Immigration Bond, has coverage
under the following PIAs and SORNs:
•
•
•
•
•
•
•

DHS/ICE/PIA-005(a) Bond Management Information System 2009
DHS/ICE/PIA-005 Bond Management Information System 2008
DHS/ICE-PIA-015(b) EID EARM 3.0
DHS/ICE/PIA-008 eBonds Online System
DHS/ICE-004 Bond Management Information SORN
DHS/ICE 011 – CARIER SORN
DHS/USCIS/ICE/CBP-001 - Alien File, Index, and National File Tracking System of
Records (A-FILE SORN)

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

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

Hannah Burgess

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1184356
August 23, 2019
August 23, 2022

DESIGNATION
Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☒ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

DHS IC/Forms Review:

Choose an item.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Choose an item.
Statement:
Statement submitted and approved
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA

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

If covered by existing PIA, please list: DHS/ICE/PIA-005 Bond
Management Information System and update;
DHS/ICE-PIA-015(b) EID EARM 3.0;
DHS/ICE/PIA-008 eBonds Online System
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/ICE-004 Bond
Management Information System (BMIS) February 15, 2011 76 FR
8761;
DHS/ICE-011 Criminal Arrest Records and Immigration Enforcement
Records (CARIER) System of Records October 19, 2016, 81 FR 72080
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
ICE is submitting this updated PTA to discuss Form I-352, Immigration Bond, to document that the form
will now allow ERO to accept Maintenance of Status and Departure (MS&D) bonds. Because nonimmigrants required to post these bonds do not have A-Numbers, the revised form now collects visa
numbers as an alternative identifier. No other PII changes were made to the form.
By completing Form I-352, the bond obligor (either an individual or a surety company) provides a
formal, written guarantee as security for the amount of the bond, thereby assuring DHS that all of the
conditions of the bond will be fulfilled. In addition to A-Number and visa number, the form collects
information about the bond obligor, the alien for whom the bond is furnished, DHS employees, and
individuals who pledge bonds, notes, or cash. Forms are stored electronically in EARM, BMIS Web,
eBONDS, and the eBONDS SharePoint document repository.
PRIV finds that is a privacy sensitive system and a PIA is required because Form I-352 Immigration
Bond collects PII from members of the public. PRIV agrees with ICE Privacy that coverage is provided
by DHS/ICE/PIA-005 Bond Management Information System and the subsequent update, which discuss
the lifecycle of immigration bonds. Coverage is also provided by DHS/ICE-PIA-015(b) EID EARM 3.0,
which discusses the interfaces that provide data to EID in support of the electronic processing of
immigration bonds and DHS/ICE/PIA-008 eBonds Online System, which covers the electronic Form I352.
PRIV finds that a SORN is required because Form I-352 retrieves information by unique identifier. PRIV
agrees with ICE Privacy that coverage is provided by DHS/ICE-004 Bond Management Information
SORN, which covers records related to the administration and financial management operations of ICE's
immigration bond program. Coverage is also provided by DHS/ICE-011 CARIER SORN, which covers
records collected to support the grant or denial of parole, and tracking of individuals who seek or receive
parole into the United States, and DHS/USCIS/ICE/CBP-001 Alien File, which covers information
collected as part of an individual’s A-File.

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