Pia 15

Privacy Impact Assessment Update
for the

Computer Linked Application
Information Management System 4
(CLAIMS 4)
DHS/USCIS/PIA-015(b)
November 5, 2013
Contact Point
Donald Hawkins
Privacy Officer
United States 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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USCIS, CLAIMS 4
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Abstract
The Department of Homeland Security (DHS) United States Citizenship and Immigration
Services (USCIS) is updating the Privacy Impact Assessment (PIA) for the Computer Linked
Application Information Management System 4 (CLAIMS 4) published on August 31, 2011. 1
CLAIMS 4 is an electronic case management system used to track and process naturalization
applications. The purpose of this update is to discuss the centralization of naturalization forms
after disposition of the Reengineered Naturalization Application Casework System (RNACS).

Introduction
The United States Citizenship and Immigration Services (USCIS) modified the
administration and adjudication of naturalization and citizenship benefits by streamlining the
process and centralizing the systems used to administer these forms. The Computer Linked
Application Information Management System 4 (CLAIMS 4) replaces the Reengineered
Naturalization Application Casework System (RNACS) and serves as the primary case
management system for all naturalization applications. Individuals are instructed to file Forms
N-600, Application for Certificate of Citizenship, N-600K, Application for Citizenship and
Issuance of Certificate Under Section 322, and N-336, Request for a Hearing on a Decision in
Naturalization Proceedings (Under Section 336 of the INA) at a secure Lockbox facility instead
of the local office within their jurisdiction. This centralization effort streamlines the way forms
are processed, accelerates the collection and deposit of fees, and improves the consistency of the
administration and adjudication for these forms.
Centralization of Naturalization Forms
The former Immigration and Naturalization Service developed RNACS as an interim
system to support naturalization processing in the period between the termination of the legacy
Naturalization Application Casework System and the full deployment of CLAIMS 4. Today, the
Lockbox receives and receipts incoming forms and electronically transmits those forms to
CLAIMS 4 for processing instead of RNACS. 2 USCIS uses CLAIMS 4 to perform a variety of
automated tasks associated with processing and adjudicating applications. Its functions include
receipting, data entry, recording benefit determinations (e.g., approvals and denials), and other
operations necessary to process naturalization applications. USCIS previously used RNACS to
process these forms from initial data entry to issuance of final documents. The goal of this
initiative is to process and adjudicate all the naturalization/citizen benefits in one central system.

1

DHS/USCIS/PIA-015(a) - Computer Linked Application Information Management System (CLAIMS 4) Update is
available at www.dhs.gov/privacy.
2
For more information on the Lockbox, see DHS/USCIS/PIA-003(a) - Integrated Digitization Document
Management Program (IDDMP), available at www.dhs.gov/privacy.

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USCIS modified CLAIMS 4 to support the processing of the following naturalization
applications:
•

N-336, Request for a Hearing on a Decision in Naturalization Proceedings (Under
Section 336 of the INA) (Office of Management Budget (OMB) No. 1615-0050),
which is used by an individual to request a hearing on an unfavorable decision related
to a naturalization application;

•

N-600, Application for Certificate of Citizenship (OMB No. 1615-0057), which is
used by an individual to document U.S. citizenship status based on parentage; and

•

N-600K, Application for Citizenship and Issuance of Certificate Under Section 322
(OMB No. 1615-0087), which is used for a child who regularly resides abroad to
claim U.S. citizenship based on parentage.

USCIS instructs individuals applying for naturalization and citizenship benefits to mail
completed applications, supplemental evidence, and applicable filing fees to the USCIS
Lockbox. Each application undergoes a quality assurance review to ensure it is properly filed.
Lockbox personnel verify the completion of the following items: basic biographical information,
signature on the form, jurisdiction of the submitted form, correct fee, and basic eligibility of the
individual.
Successfully completed filings are accepted and the information is entered into CLAIMS
4 rather than RNACS. CLAIMS 4 automatically generates an application identification number,
which may be used later to check the application’s status in CLAIMS 4. USCIS sends a receipt
notice and appointment letter to the applicant indicating when and where the applicant must go
to have his or her fingerprints taken after USCIS personnel enter information from the
application into the system. USCIS continues to process naturalization and citizenship
applications as outlined in the DHS/USCIS/PIA-015 CLAIMS 4 PIA.
CLAIMS 4 collects information pertaining to the applicant, biological parent, adoptive
parent, and/or legal guardian to determine benefit eligibility. The information from these forms
is similar to the type of data collected from the Form N-400, Application for Naturalization.
This information may include: name, address, telephone numbers, birth information, Social
Security Numbers (SSN), country of citizenship, applicant and family members’ immigration
status, marital status, personal characteristics, tax and financial history, employment information,
medical information, military and selective service information, travel history, organization
membership or affiliation history, and criminal history information (to the extent such history is
revealed by the applicant in their application). New information entered into CLAIMS 4
includes adoption history. The processing of this information increases the volume of
information collected by the system, but the information collected by these applications is similar
to data currently collected by CLAIMS 4.

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With the disposition of RNACS, USCIS migrated active cases from RNACS to CLAIMS
4 for continued processing. USCIS updated CLAIMS 4 to absorb RNACS responsibilities and
functions. USCIS transferred historical data from RNACS to the enterprise Citizenship and
Immigration Service Consolidated Operational Repository (eCISCOR) 3 for archival purposes
and continued access via the USCIS Enterprise Service Bus (ESB). 4 Historical data are
adjudicated and closed cases (i.e., approved or denied applications).

Reason for the PIA Update
USCIS is updating the CLAIMS 4 PIA to describe the impact of RNACS’s disposition on
CLAIMS 4. CLAIMS 4 now provides automated support for the processing of the following
naturalization and citizenship applications: N-363, N-600, and N-600K. USCIS migrated all
active cases from RNACS to CLAIMS 4 for continued processing and adjudication.

Privacy Impact Analysis
In each of the below sections consider how the system has changed and what impact it has on the
below fair information principles. In some cases there may be no changes and indicate as such.

The System and the Information Collected and Stored within the System
USCIS updated CLAIMS 4 to administer and adjudicate naturalization and citizenship
applications that were previously processed by RNACS. CLAIMS 4 is responsible for the case
management functions for the following forms:
• N-336, Request for a Hearing on Decision in Naturalization Proceedings (OMB No.
1615-0050),
•

N-600, Application for Certificate of Citizenship (OMB No. 1615-0057), and

•

N-600K, Application for Citizenship and Issuance of Certificate Under Section 322
(OMB No. 1615-0087).

CLAIMS 4 will continue to process the N-400. USCIS reviewed all the data elements that it
collects on naturalization forms to ensure that only the minimum amount of information needed
to determine benefit eligibility and to ensure that the information increased processing
efficiency. Data that did not meet these guidelines were not included in the form. Furthermore,
all data elements collected were negotiated with and approved by OMB during Paperwork
Reduction Act (PRA) collection review.

3

DHS/USCIS/PIA-023 - Enterprise Citizenship and Immigrations Services Centralized Operational Repository
(eCISCOR) is available at www.dhs.gov/privacy.
4
DHS/USCIS/PIA-008 - Enterprise Service Bus (ESB) is available at www.dhs.gov/privacy.

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USCIS migrated all actives cases from RNACS to CLAIMS 4 for processing and
adjudication. The information derived from these forms is similar to the type of data collected
from N-400 forms. The processing of this information only increases the volume of information
collected by CLAIMS 4. Although there is a privacy risk associated with increasing the volume
of information in CLAIMS 4, this risk is mitigated by existing system protections, such as rolebased access, mandatory annual Privacy Act and computer security awareness training, audit
trails, and the implementation of appropriate IT security protocols.
Uses of the System and the Information
USCIS continues to use CLAIMS 4 as described in the DHS/USCIS/PIA-015 CLAIMS 4
PIA. USCIS modified CLAIMS 4 to support the processing of Forms N-600, N-600K, and N336 to determine benefit eligibility. USCIS offices use CLAIMS 4 to administer and adjudicate
benefits for naturalization throughout the naturalization process, from application submission to
closeout. The modifications to CLAIMS 4 were limited to the intake and final adjudication of
Forms N-600, N-600K, and N-336.
Retention
The retention has not changed with this update. The approved National Archives and
Records Administration (NARA) retention schedule [N1-563-04-04] has not changed with this
update and covers the collection of N-600, N-600K, and N-336. Information in the system from
naturalization-based applications will be deleted 15 years after a final decision is made on the
case (i.e., approved, denied, withdrawn, and any appeals process). USCIS consolidates these
forms into the Alien File [N1-566-08-11]. There is no further privacy impact since retention
remains the same.
Internal Sharing and Disclosure
Internal sharing and disclosure of information has not changed with this update. USCIS
will continue to share information with agencies internal to DHS as outlined in the
DHS/USCIS/PIA-015 CLAIMS 4 PIA and its corresponding updates.
External Sharing and Disclosure
The external sharing and disclosure of information has not changed with this update.
USCIS will continue to share information with agencies external to DHS as outlined in the
DHS/USCIS/PIA-015 CLAIMS 4 PIA and its corresponding updates.

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Notice
USCIS provides notice through this PIA update. The DHS-USCIS-007 Benefits
Information System (BIS) System of Records Notice (SORN), September 29, 2008, 73 FR
56596, covers the collection, use, and disclosure of data with these updates. Additionally,
USCIS provides a Privacy Act Statement as required by Section (e)(3) of the Privacy Act to
individuals who apply for naturalization benefits prior to the collection of information. The
Privacy Act Statement details the authority to collect the information, purpose for which the
information is used, how the information is going to be used outside of the agency, and whether
providing the information is mandatory. USCIS provides the individual with the Privacy Act
Statement on the Form Instructions for each Form.
Individual Access, Redress, and Correction
The individual right to access, redress, and correction has not changed with this update.
Customers maintain the right to file a Freedom of Information Act (FOIA) and/or Privacy Act
(PA) request to gain access to or amend their USCIS records. Any individual seeking to access
information maintained in CLAIMS 4 should direct his or her request to USCIS National
Records Center (NRC), P.O. Box 648010, Lee's Summit, MO 64064-8010. This update creates
no increased privacy impact.
Technical Access and Security
The technical access and security controls for CLAIMS 4 has not changed with this
update. USCIS continues to employ technical and security controls to preserve the
confidentiality, integrity, and availability of the system, which is validated during the security
authorization process. 5 These security controls mitigate privacy risks associated with
unauthorized access and disclosure.

5

The security authorization process substantiates the implementation of security standards and guidelines for
information systems.

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Technology
USCIS modified CLAIMS 4 to support the administration and adjudication of three
additional naturalization forms in order to centralize the processing of naturalization
applications. CLAIMS 4 continues to serve as the case management system to process
naturalization and citizenship benefits. The centralization of these forms provides applicants
with faster and more efficient application processing and consistent adjudication. Although
technology modifications may create privacy risk, USCIS mitigates this risk by implementing
appropriate controls to maintain compliance with the Federal Information Security Management
Act.

Responsible Official
Donald Hawkins, Privacy Officer
United States Citizenship and Immigration Services
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