PIA 016a

Privacy Impact Assessment Update
for the

Computer Linked Application
Information Management System
(CLAIMS 3) and Associated Systems
DHS/USCIS/PIA-016(a)
March 25, 2016
Contact Point
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
(202) 272-8030
Reviewing Official
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 1

Abstract
U.S. Citizenship and Immigration Services (USCIS) oversees lawful immigration to the United
States and is responsible for processing petitions, applications, and other requests for immigration
benefits. USCIS uses the Computer Linked Application Information Management System (CLAIMS 3)
and associated systems to manage the adjudication process for most domestically-filed, paper-based,
immigration benefit filings with the exception of naturalization, intercountry adoption, and certain
requests for asylum and refugee status. USCIS is updating this Privacy Impact Assessment (PIA) to
evaluate the privacy risks and mitigations associated with the collection, use, and maintenance of
personally identifiable information (PII) provided by individuals seeking requested immigration related
benefits.

Overview
U.S. Citizenship and Immigration Services (USCIS) receives and adjudicates petitions,
applications, and other requests (hereinafter referred to as “benefit requests”) for many United States
immigration benefits. This PIA covers the adjudication process and USCIS case management systems
for most domestically-filed, paper-based, immigration benefit filings with the exception of
naturalization, intercountry adoption, and certain requests 1 for asylum and refugee status. USCIS uses
different data systems to capture and store information provided by benefit requestors, including the
Computer Linked Application Information Management System (CLAIMS 3), the Interim Case
Management System (ICMS), and Marriage Fraud Amendment System (MFAS), collectively referred
to as “CLAIMS 3 and associated systems.”
USCIS processes different benefit requests using different case management systems, subsystems, tracking tools, and data aggregation tools for reporting. This process creates duplicate records
and data integrity concerns. USCIS is slowly transitioning benefit request processing to the USCIS
Electronic Immigration System (USCIS ELIS), which will alleviate some of these data integrity and data
minimization risks.
At a very high level, CLAIMS 3 and associated systems are old, legacy, mainframe systems that
do not have the capability to interface in real-time with other systems or to generate reports, metrics, or
aggregated statistics. But CLAIMS 3 still serves as the authoritative source case management system for
certain benefit requests because so many other tools and systems point to it.
The “certain requests” for refugee and asylum benefits include the “follow to join” petition (Form I-730). “Follow to join”
is an option offered to family members of the principal beneficiaries of approved asylum and refugee status. Immediate
family members (spouses and children under the age of 21) may qualify for derivative status. An individual who entered the
United States and was granted asylum/refugee status within the past two years may petition to have his or her spouse and/or
unmarried children “follow-to-join” him or her in the United Sates and obtain derivative status. The derivatives may be in
the United States or outside the United States.
1

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 2

Data from CLAIMS 3 is replicated across many systems and tools within USCIS due to the technical
limitations of CLAIMS 3 itself. Therefore, this PIA focuses on documenting all of the tools and
interfaces that rely on CLAIMS 3. As detailed throughout this PIA, this business process has generated
data integrity and data minimization concerns.
The three case management systems used to track and process paper-based benefit request forms
other than naturalization, intercountry adoption, and certain asylum and refugee benefits include:
•

CLAIMS 3 is the case management system that supports and maintains officer casework
documentation and tracking for most benefit requests. CLAIMS 3 functionalities include tracking
the adjudication performed by USCIS personnel, archiving, card production, case history, case
transfer, on-demand reports, electronic file tracking, image capture, production statistics, and
status update and electronic ingestion of benefit request form data captured through the
Lockbox. 2

•

ICMS is a web-based front-end to CLAIMS 3. ICMS can be used to review, modify, and track
the adjudication performed by USCIS personnel of benefit request forms.

•

Marriage Fraud Amendment System (MFAS) is a legacy mainframe case tracking system
designed to supplement the adjudication of petitions covered by the Immigration Marriage Fraud
Act of 1986 (IMFA). 3 Contrary to the name of the system, MFAS supports and maintains
casework for petitions for Legal Permanent Residency by aliens who have previously been
granted Conditional Permanent Residency under the terms of the IMFA, including entrepreneurs.
MFAS facilitates the adjudication and notification process for this program.
When a petition to remove the terms of conditional permanent residency is received, USCIS
accepts the fee and issues a receipt in CLAIMS 3, which then interfaces with MFAS to update
the case with the information that a petition has been received. When a final decision on the case
is made in MFAS and a notice is issued, the CLAIMS 3 history data for the case is updated to
reflect the decision. Once the case has been receipted in CLAIMS 3 and MFAS has been updated
with the receipt information, the case is locked in CLAIMS 3 and can be updated only in MFAS.

In general, a Lockbox is a post office box used by USCIS to accelerate the collection of receivables. The USCIS Lockbox
is used to accept applications and petitions by electronically capturing data and images from benefit request forms and by
performing fee receipting and fee deposit. See DHS/USCIS/PIA-061 USCIS Benefit Intake and Receipt Intake, available at
www.dhs.gov/privacy.
3
See Public Law 99-639, which was passed in order to deter immigration-related marriage fraud. Its major provision
stipulates that aliens deriving their immigrant status based on a marriage of less than two years are conditional immigrants.
To remove their conditional status, the immigrants must apply at an USCIS Office during the 90-day period before their
second-year anniversary of receiving conditional status. If the aliens cannot show that the marriage through which the status
was obtained was and is a valid one, their conditional immigrant status may be terminated and they may become
deportable.
2

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 3

All information maintained by CLAIMS 3 and associated systems is also replicated in the
Enterprise Citizenship and Immigrations Services Centralized Operational Repository (eCISCOR) for
reporting, statistical analysis, and adjudicatory purposes 4 that CLAIMS 3 and associated systems are
unable to perform.
Using a data repository such as eCISCOR protects CLAIMS 3 and associated systems from
undue resource strain. eCISCOR transfers data from nearly all USCIS live transactional systems. Due to
the age of many legacy USCIS live transactional systems, and the high volume of cases they process,
USCIS requires eCISCOR (and other backend storage systems) to reduce the labor and system strain
involved in accessing, reporting, and sharing information between USCIS systems.
Preliminary Review of Application:
As described in the Benefit Request Intake Process PIA, when a benefit requestor, 5 accredited
representative, 6 or legal representative 7 (hereafter collectively referred to as legal representative) submits
a form to USCIS, USCIS preliminarily reviews the form for completeness. 8 As part of the preliminary
review, USCIS assigns the benefit requestor or beneficiary 9 an Alien Number (A-Number) 10 or matches
the request with an existing A-Number (if applicable), 11 assigns the application a Receipt Number, 12 and
forwards the benefit request form, to be consolidated in the Alien File (A-File) 13 or Receipt File, 14 to the
appropriate USCIS office for adjudication.
See DHS/USCIS/PIA-023(a) Enterprise Citizenship and Immigrations Services Centralized Operational Repository
(eCISCOR), available at www.dhs.gov/privacy.
5
Individuals who have filed for immigration benefits for themselves are collectively referred to as benefit requestors.
6
A person who is approved by the Board of Immigration Appeals (the Board) to represent aliens before the Immigration
Courts, the BIA and USCIS. He or she must work for a specific nonprofit, religious, charitable, social service, or similar
organization. The organization must be authorized by the Board to represent aliens.
7
An attorney or a BIA-accredited representative can represent a benefit requestor before USCIS, as a legal representative
with an approved G-28, Notice of Entry of Appearance as Attorney or Accredited Representative on file.
8
See DHS/USCIS/PIA-061 Benefit Request Intake Process PIA (March 16, 2016), available at www.dhs.gov/privacy.
9
An alien who is sponsored by a relative or a business, or has self-petitioned for an immigration benefit.
10
The Alien Number is a unique seven-, eight- or nine-digit number assigned to a noncitizen at the time his or her A-File is
created.
11
As a general matter, USCIS does not create an Alien Number on a native born U.S Citizen. However, in the event that a
person (native born or naturalized) decides that he or she does not want to be a U.S. citizen, he or she may formally
renounce his or her citizenship through Department of State (DOS). DOS sends a Certificate of Loss of Nationality to
USCIS to be filed in an A-File for this purpose. In such circumstance an A-File will be created.
12
The receipt number is a unique 13-character identifier that USCIS provides for each application or petition it receives.
The agency uses it to identify and track its cases. The receipt number consists of three letters-for example, EAC, WAC,
LIN, SRC, NBC, MSC, YSC, AAO, or IOE-and 10 numbers.
13
An A-File is a paper or electronic-based file that contains official immigration records of aliens or persons who are not
citizens or nationals of the United States, as well as U.S. born citizens involved in certain immigration crimes. A-Files
contain all records pertaining to naturalized citizens and any active case of an alien not yet naturalized, including records
created as he or she passes through the U.S. immigration and inspection process and, when applicable, records related to
any law enforcement action against or involving the alien.
14
Receipt Files are files of immigrant and nonimmigrant benefit filings that USCIS receives. While the Receipt Files and
4

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 4

CLAIMS 3 manages many types of benefit request forms, each with its own unique eligibility
requirements and required data elements. 15 USCIS personnel review the benefit request package (to
include the form and supplemental evidence) and enter relevant and necessary information from the
benefit request form into CLAIMS 3, including the A-Number. CLAIMS 3 is configured to collect
certain data elements based on the benefit being sought for adjudicative tracking and case management
purposes.
When a new case is created in CLAIMS 3, the system electronically sends A-Numbers to the
Central Index System (CIS) to either create a record or update an existing record. 16 The purpose of CIS
is to provide a searchable central index of A-Files and to support the location and transfer of A-Files
among DHS personnel and offices as needed in support of immigration benefits and enforcement actions.
CIS helps ascertain an individual’s current immigration status and prior status. CIS returns information
associated with the A-Number, including name, date of birth, and country of birth for verification
purposes. CLAIMS 3 also interfaces with the National File Tracking System (NFTS), which is an
automated file-tracking system used to maintain an accurate file inventory and track the physical location
of files (i.e., A-Files and Receipt Files), to share file location information about newly receipted
applications, and to electronically input the A-Number, Receipt Number, and File Control Office (FCO)
to the NFTS. 17
When a user requires the A-File, the user goes to CIS and requests the file. CIS has a direct
interface with NFTS, and receives the following information from it on the applicant: full name, the
primary tracking number A-Number) and date of birth. NFTS maintains this information in order to
control the inventory of all files, query the file location, manage the request and transfer of files between
offices and to/from the FCOs, provide reports to support management and cleanup efforts, and gather
statistical information to improve the records processes. NFTS does not store a digitized copy or the
entire content of the immigration files. When the FCO receives the request for the A-File, the A-number
and the person’s full name and date of birth are printed on the pull ticket so that the FCO can verify the
correct A-File is being pulled. When a user requires any file other than the A-File, he or she must go into
NFTS directly and using the primary tracker number, submit a request for the File. The pull ticket only
has the primary tracker number and no other information.

supporting documentation are eventually consolidated into an A-File, Receipt Files allows USCIS adjudicators to begin
processing cases in a quick and efficient manner.
15
See Appendix A for a full list of benefit request forms processed by CLAIMS 3.
16
See DHS/USCIS/PIA-009 Central Index System (CIS), available at www.dhs.gov/privacy.
17
See DHS/USCIS/PIA-032 NFTS, available at www.dhs.gov/privacy.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 5

Case Processing
Each USCIS regional field office is responsible for reviewing benefit request forms under its
jurisdiction and may identify cases ready for adjudicative review either manually or electronically. Each
Service Center has developed tools and methods that use CLAIMS 3 data to separately manage and
prioritize cases. See Appendix B for a complete description of these tools and methods.
As noted above, USCIS uses CLAIMS 3, which contains information provided by the individual
on the benefit request form, to process and adjudicate benefit request forms. Information from the benefit
request forms may vary depending on the benefit request sought by the individual. Additionally, USCIS
records adjudicative steps that have been completed in CLAIMS 3, such as appointments to submit
biometrics, other benefit request receipts pending with USCIS, the issuance of a notice, and a flag
indicating suspected fraudulent activity or referral to Fraud Detection and National Security (FDNS)
Directorate.
USCIS personnel review all case-related information provided by the benefit requestor or his or
her representative, including supplementary evidence and review the A-File (if available) to verify the
identity and benefit eligibility of the benefit requestor. In limited circumstances, USCIS may use other
systems to automate the case processing and adjudication for certain benefit requests (based on the
service center location or form type). The system evaluates each case to determine if it meets all
eligibility criteria. 18 Cases that meet the criteria are batched for quality review by USCIS personnel prior
to noting approval in CLAIMS 3. Cases that do not meet the eligibility criteria are batched for manual
officer adjudication. See Appendix C for a complete description of the systems used to support
automated adjudication.
A-File Review, if applicable
USCIS personnel may retrieve and review an individual’s physical or electronic A-File (via the
Enterprise Document Management System (EDMS)) when adjudicating a benefit request form. 19 USCIS
USCIS uses CasePro (See DHS/USCIS/PIA-040 CasePro available at www.dhs.gov/privacy) and System Electronic
Registration Approval (SERA) (See DHS/USCIS/PIA-058 SERA, available at www.dhs.gov/privacy.) to automate the
processing of Temporary Protected Status (SERA Only), Deferred Action for Childhood Arrivals (DACA), and Deferred
Enforced Departure (DED) filings. Benefit requestors submit these filings within a select and short filing period.
During the filing period, the Vermont Service Center (VSC) or California Service Center (CSC) may experience a
significant increase of filings causing processing delays. The manual adjudication of these benefits are time-consuming, and
limited the number of cases an adjudicator is able to complete on a daily basis. Through automated processing, both
CasePro and SERA streamline the adjudication process for the aforementioned filings and significantly reducing the case
processing times.
18

19
EDMS is a web-based system that allows authorized users to view and search electronic copies of the paper-based case
files.
Prior to the implementation of EDMS, USCIS manually provided case files to the USCIS, ICE, or CBP in need of the file.
USCIS developed EDMS to facilitate efficient information sharing. See DHS/USCIS/PIA-003(a) Integrated Digitization
Document Management Program (IDDMP), available at www.dhs.gov/privacy.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 6

personnel may consolidate the form, supporting documentation, and any other case information into the
individual’s A-File. USCIS personnel may also use the A-File to determine if the benefit requestor or
beneficiary has had prior involvement with USCIS or any other DHS Components, such as U.S.
Immigration and Customs Enforcement (ICE) or U.S. Customs and Border Protection (CBP) which also
contribute to and manage A-File content. 20 This review may provide information relevant to establishing
eligibility for the immigration benefit being sought.
Supporting Documentation and Notices
USCIS requires supporting documentation (submitted by the requestor) as initial evidence of a
benefit requestor’s identification and eligibility for a benefit. Examples of supporting documentation
include: copies of civil documents such as birth, marriage, or adoption certificates; divorce decrees;
affidavits of financial support; criminal records; and school records. Certain forms require individuals
to provide credible evidence establishing a relationship between the benefit requestor and beneficiary. 21
If a benefit requestor or beneficiary fails to submit evidence or provides insufficient evidence to
establish eligibility, USCIS will use the information stored in CLAIMS 3 to issue a Request for Evidence
(RFE) 22 or Notice of Intent to Deny (NOID) 23 for continued processing. USCIS personnel use a
correspondence generator tool to create and store most correspondence, including RFEs and NOIDs.
These correspondence generator tools create RFEs and NOIDs using pre-defined templates and standard
text.24 In order to generate notices, USCIS personnel manually enter data into the correspondence
generator tool or the tool receives information directly from CLAIMS 3 or eCISCOR. USCIS sends the
notices directly to the benefit requestor and/or her or his representative with instructions on how to
respond. If a Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative, is on
file with USCIS, then USCIS sends copies of the notices to legal representatives. If the benefit requestor

When a foreign citizen enters the United States legally or illegally, USCIS, ICE, or CBP assigns the individual an Anumber. In the event that an individual was inadvertently issued more than one A-Number, USCIS lists all A-Numbers in
his or her CIS record. USCIS consolidates all A-Numbers in CIS by identifying primary and secondary A-Numbers. A
primary A-Number is the number currently assigned to the surviving physical paper file and it the first number listed in
CIS. Secondary A-Numbers are those that been consolidated into the primary A-Number, and are listed below the primary
number.
21
For example, Form I-730. Certain petitions allow individuals to petition on behalf of family members (children and
spouses). To prove a child-parent relationship, a birth certificate maybe required. Evidence of any legal change must also be
submitted if the names on the birth certificate do not match the names on the petition.
22
USCIS uses an RFE when an application lacks required documentation or the adjudicator needs additional evidence to
determine an applicant’s eligibility for the benefit sought. The request will indicate what evidence or information USCIS
needs to fully evaluate the application or petition under review.
23
A NOID is a formal statement from USCIS that it has determined that the applicant is ineligible for the immigrant benefit
requested. The issuance of a NOID is required when derogatory information is uncovered during the course of the
adjudication that is not known to the individual, according to 8 CFR § 103.2(b)(16). However, USCIS will grant the
applicant an opportunity to overcome this determination and demonstrate that he or she is eligible.
24
See the forthcoming USCIS Benefit Decision and Output PIA for more information, available at www.dhs.gov/privacy.
20

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 7

or legal representative does not respond to the RFE or NOID by the required date set by USCIS, USCIS
may deny the benefit request. 25
Screening (Background, Identity, and Security Checks)
All individuals submitting benefit requests are subject to background, identity, and security
checks to ensure eligibility for the requested benefit and to ensure that they do not pose a threat to public
safety or to the national security of the United States. 26 USCIS conducts background, identity, and
security checks as part of case processing. USCIS requires benefit requestors and beneficiaries for certain
immigration benefits to submit their biometrics along with and biographic information provided in the
benefit request to USCIS for background, identity, and security checks.
Once USCIS receives the completed benefit request form, USCIS schedules individuals to be
fingerprinted and have their photograph taken at an Application Support Center (ASC). USCIS uses the
National Appointment Scheduling System (NASS) to schedule appointments for fingerprinting at an
ASC. USCIS personnel may schedule appointments automatically or manually. 27 NASS automatically
generates appointments on a weekly basis through an interconnection with CLAIMS 3. USCIS personnel
may manually expedite the process by requesting an appointment for certain benefit requestors directly
in NASS.
USCIS collects biometric data at an authorized biometric capture site, including USCIS offices
and ASC. At the biometric collection site, USCIS electronically captures the benefit requestor’s
fingerprints and related biographic data required to verify the individual’s identity and to ensure that the
correct biographic information is associated with the captured biometrics. Biometric data is captured in
Customer Profile Management System (CPMS), which is the centralized source of biometric images
used for USCIS benefit card and document production. 28 Biometric and biographic data are also sent
from the respective USCIS case management system to the print production systems, where a card is
produced. For CLAIMS 3, an individual’s photograph, signature, and fingerprints are digitally sent to
and stored in the Biometric Retrieval Utility (BRU), which is a subsystem of CLAIMS 3, and is used for
card production purposes.
USCIS manually enters background and security check results into CLAIMS 3 with the exception
of the results of Federal Bureau of Investigation (FBI) fingerprint checks. 29 This information includes:
Generally, the standard maximum response time is 12 weeks (84 days). Adjudicators, in their discretion, may reduce the
standard response time only after obtaining supervisory concurrence. This discretion may be used on a case-by-case basis
when warranted by circumstances as determined by the adjudicators and the supervisor.
26
See DHS/USCIS/PIA-033 Immigration Benefits Background Check Systems (IBBCS) and DHS/USCIS/PIA-060
Customer Profile Management System, available at www.dhs.gov/privacy.
27
See DHS/USCIS/PIA-057 NASS, available at www.dhs.gov/privacy.
28
See DHS/USCIS/PIA-060 Customer Profile Management Service available at www.dhs.gov/privacy.
29
USCIS conducts both biometric and biographic background, identity, and security checks by querying a number of
USCIS, DHS, and other U.S. Government systems. These checks allow USCIS to determine if the individual is who he or
25

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 8

the source and date of the background check, the return of any unclassified derogatory results and
whether the results were resolved, and the expiration date of the results. All background, identity, and
security check results are either initiated through manual or electronic processes outside of CLAIMS
3. 30 A summary of the background, identity, and security check may also be printed and stored in an AFile, but is not stored in CLAIMS 3.
Information from benefit request forms maintained in CLAIMS 3 may also be referred to the
FDNS Directorate, through manual or automated referral processes for screening and for investigation
of fraud, public safety, and/or national security concerns. The DHS/USCIS/PIA-013-01 FDNS and
DHS/USCIS/PIA-013 FDNS-DS PIAs provide an in-depth discussion of the FDNS Directorate and
automated screening evaluating the privacy risks and mitigation strategies built into each process. 31
Interview
USCIS conducts interviews for certain benefit requests as part of the benefit adjudication process.
A benefit requestor or beneficiary may be required to appear for an interview at a domestic Field Office.
Adjustment of Status (AOS) Scheduler, a CLAIMS 3 subsystem, is used to schedule interview
appointments, to track the date and status of interview appointments, and to generate interview notices.32
AOS Scheduler stores the date, time, location, status of interview, and notice sent date. USCIS personnel
mail the Interview Notice to the benefit requestor and, if applicable, his or her legal representative.
Interview information is also added to the A-File, as required by case adjudication Standard Operating
Procedures (SOPs).
All individuals who arrive at a USCIS Field Office for an interview are biometrically verified via
photographs and two fingerprints (2-print) verification. USCIS uses a verification tool called Identity
Verification Tool (IVT). 33 IVT allows USCIS Field Offices to compare an individual’s biometric
(fingerprint and photograph) and biographic information to information previously captured at an ASC,
ensuring that the person who appeared at the ASC is the same person appearing at the USCIS Field
Office.
she purports to be, as well as whether there are any criminal or national security-related issues associated with the benefit
requestor or beneficiary that may adversely affect his or her eligibility for the requested immigration benefits.
30
FD-258 MF, a CLAIMS 3 subsystem, maintains information on individual applicants’ fingerprint status. Each record
contains applicant information that was sent to the FBI, such as name, date of birth, and other biographical data, as well as
date fingerprinted and date sent to FBI. The records also contain other information received from the FBI such as FBI
process date and FBI search results.
31
See DHS/USCIS/PIA-013-01 Fraud Detection and National Security Directorate (FDNS) and DHS/USCIS/PIA-013
Fraud Detection and National Security Data System (FDNS-DS), available at www.dhs.gov/privacy.
32
In the future, USCIS plans to update NASS to schedule interviews for CLAIMS 3. NASS is currently limited to
scheduling appointments for biometric appointments and the system is being developed in phases to ensure the system
sufficiently works. USCIS plans to expand NASS to schedule interview and other appointments until then legacy AOS is
used.
33
See DHS/USCIS/PIA-060 Customer Profile Management System, available at www.dhs.gov/privacy.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 9

During the course of the interview, USCIS Field Officers may use web cameras to digitally record
immigration interviews. 34 The recordings are temporarily recorded on a workstation and then converted
onto an encrypted digital optical disc storage (i.e., DVD). Once copied, the recordings are permanently
erased from the workstation. The digital disc with recorded immigration interviews is then stored in the
related A-File.
Decision Case Action
After all the steps discussed above are complete, USCIS personnel make a final determination
on the benefit request. USCIS personnel may grant, deny, or revoke an immigration benefit. USCIS
personnel may also allow the benefit requestor or beneficiary to withdraw his or her request for the
benefit. In certain circumstances, a benefit request may also be administratively closed. Case decision
actions are tracked and recorded in CLAIMS 3.
Following an adjudication decision, USCIS uses various tools to generate correspondence and
print documents. This process is further detailed in the forthcoming USCIS Benefit Decision and Output
PIA. 35
Post-Decision Reporting

USCIS uses the information contained in CLAIMS 3 to generate a number of statistical reports
to measure and evaluate workload for proper resource allocation. CLAIMS 3 interfaces with the Standard
Management Analysis and Reporting Tool (SMART) (which pulls information from eCISCOR 36) to
create customizable reports for a variety of purposes. 37 SMART uses CLAIMS 3 data to generate reports
to identify pending cases and to measure productivity trends and average processing times. USCIS also
generates granular level reports to identify types, number, and status of cases located in a particular
office or assigned to a particular USCIS staff member, which allows supervisors to identify the oldest
cases in queue for processing.

8 C.F.R. § 335.2 (c) states that USCIS officer’s conducting an examination of the applicant for naturalization may have a
videotaped transcript of the interview made, and the applicant and the Agency shall have the right to present such
documentary evidence as may be required for a full and true disclosure of the facts. The recordings provide a complete record
of the proceedings, which, in certain instances, may lead to enhanced detection of fraud and national security issues.
35
See the forthcoming USCIS Benefit Decision and Output PIA, available at www.dhs.gov/privacy.
36
See DHS/USCIS/PIA-023(a) eCISCOR, available at www.dhs.gov/privacy.
37
See DHS/USCIS/PIA-050 Standard Management Analysis Reporting Tool (SMART), available at
www.dhs.gov/privacy.
34

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 10

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?

Section 103 of the Immigration and Nationality Act (INA) provides the legal authority for this
system. 38

1.2

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

The following SORNs cover the collection, maintenance, and use of the information contained in
CLAIMS 3 and associated systems:
•

•
•

Alien File, Index, and National File Tracking System 39 covers the collection, use, and
maintenance of applications and supplemental evidence, in addition to other information related
to the individual as he or she passes through the immigration process;
Background Check Service 40 covers background checks and their results; and
Benefits Information System 41 covers the collection and use of immigrant and non-immigrant
benefit applications, decisional data, and associated fees for adjudication.

1.3

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

CLAIMS 3, includes the Mainframe, Local Application Network (LAN), ICMS, and MFAS. The
CLAIMS 3 LAN, including ICMS and MFAS as subsystems and CLAIMS 3 Mainframe (MF) Security
Plans were completed on September 3, 2015 and October 14, 2015, respectively. The CLAIMS 3 LAN
and MF Authority to Operate (ATO) are pending the publication of this PIA. CLAIMS 3 LAN and MF
will enter into the Ongoing Authorization program, upon completion of this PIA. Ongoing Authorization
requires CLAIMS 3 LAN and MF to be reviewed on a monthly basis and to maintain its security posture
in order to retain its ATO.
All minor subsystems for CLAIMS 3 and associated systems are listed in Appendix D.

8 U.S.C. § 1103.
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 78 FR 69864 (Nov. 21,
2013).
40
DHS/USCIS-002 Background Check Service, 72 FR 31082 (June 5, 2007).
41
DHS/USCIS-007 Benefits Information System, 73 FR 56596 (Sept. 29, 2008).
38
39

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 11

1.4

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

USCIS is working with NARA to update and consolidate the current retention schedules N1563-04-03 and N1-566-08-12. Under the proposed update to retention schedules for CLAIMS 3, the
system will delete and destroy records from 15 to 50 years from the date of the last completed action.
This expanded retention schedule allows USCIS to address any follow-up inquiries or requests related
to the application, including inquiries related to law enforcement, public safety, national security, and
Freedom of Information Act and Privacy Act (FOIA/PA) matters.

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.

Yes. Information collected through this process is covered by the PRA. A list of the immigration
forms processed in CLAIMS 3, along with the OMB Control Numbers is available in Appendix A.

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

2.1

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

CLAIMS 3 and associated systems maintain information from in-process and adjudicated benefit
requests. The information extracted from benefit request forms varies and not all forms collect the same
information. Information in CLAIMS 3 and its associated systems may include the following data
elements:
Names: first name, last name, middle name, and any aliases of the benefit requestor, beneficiary,
or family members. USCIS also collects names from sponsors, preparers, attorneys, and designated
representatives.
Immigration Status: e.g., Lawful Permanent Resident, U.S. citizen, or parolee, relating to the
benefit requestor, beneficiary, family member and sponsor.
Travel Information: Immigration status upon entry into the United States, days spent outside
the United States, dates of entry, port of entry, 42 immigration status expiration dates, and destination in
the United States.
42

Travel information is collected from the benefit request form, not from a system-to-system interface with CBP.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 12

Marital Status and History: USCIS collects information regarding current and former marital
status (i.e., the marital status of the benefit requestor or beneficiary, the dates of and place of marriages
or terminations, and the reason for termination).
Addresses: Benefit requestors, beneficiaries, family members, sponsors, attorneys, and
representatives. For certain benefits, a benefit requestor or beneficiary can provide both a home address
and a safe address. 43
Telephone and Facsimile Numbers: Benefit requestors, beneficiaries, family members,
sponsors, household members, attorneys, and representatives.
E-mail Addresses: Benefit requestors, beneficiaries, family members, attorneys, and
representatives.
Dates of Birth and Age: Benefit requestors, beneficiaries, sponsors, and family members.
Unique Identifying Numbers: USCIS collects A-Numbers, Social Security numbers (SSN),
USCIS ELIS account numbers, receipt numbers, and other identifying numbers of benefit requestors,
beneficiaries, family members, and sponsors.
Citizenship/Nationality: USCIS collects information on the benefit requestor, beneficiary, or
family member’s country of citizenship or nationality, and country of birth.
Travel Information: USCIS collects information on the benefit requestor, beneficiary, or family
member’s port of entry, arrival and departure dates, passport number, passport place of issue, passport
issue date, passport expiration date, travel document number, travel document country of issue, and
travel document expiration date.
Gender: Benefit requestors, beneficiaries, and family members.
Personal Characteristics: Benefit requestor or beneficiary’s hair color, eye color, height,
weight, race, and ethnicity.
Information about the attorney, representative, preparer or interpreter: Full name, business
or organization, mailing address, e-mail address, phone number, fax number, signature, language spoken,
relationship to the benefit requestor or beneficiary (if applicable). USCIS also collects Attorney Bar
Number or equivalent, Bar Membership, Accreditation Date, Board of Immigration Appeals
Representative Accreditation Expiration Date, and Law Practice Restriction Explanation.
Biometrics: Benefit requestor or beneficiary’s biometric images such as press-print, photograph,
details about those images (e.g., capture date), and signature of benefit requestor, beneficiary, interpreter,
and representative.
Benefit requestors may use an alternative mailing address, a “safe address,” on their benefit requests. USCIS will use this
safe address as the mailing address for all correspondence regarding the victim’s immigration relief. Using a safe address
protects the victim’s privacy and maintains confidentiality.
43

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 13

Card Data: Includes details about cards issued for approved applications such as card serial
number, RFID data associated with the Employment Authorization Document and the Permanent
Resident Card, production site, production status, and time/date stamp of cards.
Tax and Financial Information: USCIS collects tax identification numbers, and financial
information (check information, bank account numbers, credit card numbers (the last four digits only)
and other tax and financial information information).
Results of Background Identity and Security Checks: Date of the background check, whether
the check returned any derogatory results, whether those results were resolved, and expiration date of
the results.
Certifying Agency Information (if applicable): 44 Information collected about the certifying
agency includes agency name, certifying official name, title of certifying official, address, phone, fax,
agency type, case status, agency category, case number, FBI Number, or State Identification (SID)
Number.
Medical Information: USCIS collects medical information to establish that an applicant is not
inadmissible to the United States on public health grounds, as well as in support of a request for an
accommodation during an interview. Such information may indicate alcoholism, declaration of
incompetence, or family medical history.
Employment Information: USCIS collects employment information (place and address of
employment/occupation, type of work, employer name, length of employment, spouse’s employment)
in CLAIMS 3 to determine the benefit requestor and beneficiary’s eligibility.
Military and Selective Service Information: USCIS collects information evidencing Selective
Service registration and military service (e.g., Selective Service number, date of registration, application
for military exemption, military branch, willingness to bear arms for the United States of America) in
CLAIMS 3 to verify that the benefit requestor or beneficiary has registered with Selective Service as
required by law.
Information Regarding Organization Membership or Affiliation: USCIS collects
information regarding an applicant’s organization memberships and affiliations (organizations,
associations, clubs, foundations, parties, societies, or similar groups; communist party membership;
totalitarian party membership; terrorist organization membership) in CLAIMS 3 to determine whether
For certain immigration benefits, individuals are required to work with an agency who certifies that the individual “has
been helpful, is being helpful, or is likely to be helpful” in the investigation or prosecution of the criminal activity.
Certifying agencies include federal, state, or local law enforcement agencies, prosecutors, judges, or other authority that
investigates or prosecutes criminal activity. Other agencies such as child protective services, the Equal Employment
Opportunity Commission, and the Department of Labor also qualify as certifying agencies since they have criminal
investigative jurisdiction within their respective areas of expertise. See 8 CFR § 214.14(a)(2).

44

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 14

the applicant poses a security threat to the United States or individuals or has participated in activities
that may disqualify him or her for a requested benefit.
Criminal History or Involvement and Moral Character Issues: 45 USCIS collects information
regarding an applicant’s criminal history, involvement in criminal activities, and information regarding
moral character in CLAIMS 3 to assess whether the applicant meets the standards contained in the INA.
Case Processing Information: USCIS records case processing information such as date USCIS
received or filed benefit requests; benefit request status; location of record; other control number when
applicable; fee receipt data; status of USCIS appointments and interviews; date of issuance of a notice,
and whether the benefit request form was referred to FDNS for review.
Final Decision: Includes a notice to the benefit requestors, beneficiary, and/or the representative
on record, approval/denial code, etc.
Many USCIS forms require the submission of supplemental forms to establish eligibility for the
benefit. Examples of supplemental evidence may include, but is not limited to, marriage certificates,
birth certificates, tax records, court records, appeals and motions, personal narratives, and affidavits and
sworn statements (of benefit requestors and qualifying witnesses) including details of victimization,
criminal records, and terrorist engagement. The supplemental information is stored in the A-File.

2.2

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

Information within CLAIMS 3 is derived from the following sources: (1) benefit requestors,
beneficiaries, accredited representatives, form preparers, and/or interpreters, (2) internal DHS systems,
and (3) external systems.
Most of the information in CLAIMS 3 is derived from the data provided by the benefit requestor
or beneficiary on the completed immigration form and documentation in support of his or her benefit
request. CLAIMS 3 either automatically receives benefit request form information from an
interconnected system or USCIS staff manually enter information submitted on the USCIS form into
CLAIMS 3. Most background check results are also manually entered into CLAIMS 3. Certain
background check results are uploaded into CLAIMS 3 in a semi-automated batch process. Please see
the Appendices for a full list of immigration forms and background checks tracked in CLAIMS 3.
USCIS Systems
•

45

CIS sends A-Number verification.

See INA §101(f), § 316(e), and 8 CFR § 316.10

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 15

•

Fingerprint Processing Mainframe (FD-258 MF), a module of CLAIMS 3 MF, sends
fingerprint and name check results to CLAIMS 3. 46

•

MFAS, a module of CLAIMS 3, sends Conditional Permanent Residency approval to
CLAIMS 3.

•

Private Attorney Maintenance System (PAMS), a module of Refugee, Asylum, and
Parole System (RAPS), sends attorney data confirmation to CLAIMS 3.

•

RAPS, sends applicant address changes and employment authorization to CLAIMS 3. 47

•

CPMS sends name, receipt number, date of birth, A-Number, and SSN, if applicable.

•

Integrated Card Production System sends the status of card production to CLAIMS 3. 48

•

NFTS sends file location to CLAIMS 3.

DHS Systems
•

ICE Student and Exchange Visitor Information System (SEVIS) sends SEVIS processing
status from SEVIS to CLAIMS 3. 49

External Systems
•

FBI/Central Records System and Universal Index sends name check results to FD-258,
which then automatically sends information to CLAIMS 3. 50

•

Department of Labor/Permanent Labor Certification (PERM) and iCERT provides
CLAIMS 3 information regarding permanent and temporary labor certifications and nonimmigrant labor condition applications submitted by employers for Department of Labor
approval.

FD-258 MF is a module of the USCIS MF application CLAIMS 3 MF. FD-258 MF maintains information on individual
applicants’ fingerprint status. FD-258 MF contains applicant information that was sent to the FBI, such as Name, Birth
Date, and other biographical data, as well as Date Fingerprinted and Date Sent to FBI. It also contains other information
received from the FBI such as FBI Process Date and FBI Search Result. See DHS/USCIS/PIA-033 Immigration Benefits
Background Check Systems (IBBCS), available at www.dhs.gov/privacy.
47
See DHS/USCIS/PIA-027(b) Refugees, Asylum, and Parole System (RAPS) and the Asylum Pre-Screening System
(APSS) Update, available at www.dhs.gov/privacy.
48
ICPS prepares, manages, and processes benefit card order requests from internal and external interfacing systems. See
forthcoming Benefit Decision and Output PIA, available at www.dhs.gov/privacy.
49
SEVIS is an ICE Internet-based application for electronically tracking and reporting on foreign students, Exchange
Visitors (EV), and their dependents in the United States. SEVIS enables schools and program sponsors to transmit data
electronically to the DHS and the Department of State (DOS) throughout a students or EV’s program in the United States.
See DHS/ICE/PIA-001(a) Student and Exchange Visitor Information System II (SEVIS), available at
www.dhs.gov/privacy.
50
DOJ/FBI-002 Central Records System, 66 FR 29994 (June 4, 2001).
46

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 16

2.3

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

No.

2.4

Discuss how accuracy of the data is ensured.

USCIS collects information primarily from the benefit requestor or beneficiary or his or her
representative. CLAIMS 3 also receives information from USCIS, DHS, and external government
systems. CLAIMS 3 helps validate data entry through program coding to mitigate or prevent
inconsistencies in applicant data and in decision processing entries (e.g., the system rejects 00/00/00
birthdates).
Data is entered into CLAIMS 3 automatically and manually. Almost all information is input into
CLAIMS 3 automatically except:
•

USCIS staff may manually enter information submitted on a USCIS benefit request form into
CLAIMS 3 (during the initial intake process); and

•

USCIS manually enters background and security check results into CLAIMS 3 with the
exception of the results of FBI fingerprint checks.

For manually entered data, all USCIS data entry personnel are provided with the opportunity to
review and edit information prior to and after its submission. USCIS personnel verify the accuracy by
comparing information provided by the individual with information contained in the individual’s A-File
and from federal law enforcement systems. USCIS also verifies data accuracy with the benefit requestor
or beneficiary during the interview process. USCIS personnel can correct and edit inaccuracies at any
stage of the process.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk of inaccurate data due to manual data entry throughout the
adjudication process.
Mitigation: USCIS partially mitigates this risk through training, supervisor reviews, and ongoing
quality assurance reviews. To establish and maintain quality and consistency in processing benefit
request forms, all supervisors must ensure that all employees under their supervision involved in the
processing of benefit request forms, including the Quality Assurance Reviewer, have been trained on
these procedures. USCIS personnel and contractors who process benefit request forms are required to be
recertified every two years by receiving on-the-job training. 51
51

All immigration officers are required to take BASIC training, where human factors are involved, and demonstrates

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 17

USCIS requires supervisory reviews to be conducted by a Supervisory Immigration Services
Officer (SISO), or by an Immigration Services Officer II or higher who possesses sufficient technical
skills and significant experience in the adjudication of benefit request forms and was not involved in the
adjudication of the case. USCIS policy requires the reviewing officer to attend and complete all required
trainings.
The SISO either concurs with the officer’s recommendation or notes the reason(s) for nonconcurrence within the Adjudication Processing Worksheet, and returns the file to the adjudicating
officer for appropriate action.
During the Quality Assurance Reviews, individual case files are randomly selected and reviewed
by a team of experienced adjudicators. Reviewers use a checklist to assess and record the quality of each
case.
USCIS is working to automate the process and remove the opportunity for human error. In
addition, CLAIMS 3 and its associated systems ensure data accuracy through program coding to mitigate
or prevent inconsistencies in data and in decision processing entries by employee training. Finally during
the interview, the benefit requestor or beneficiary is able to confirm data and update information as
necessary.
Privacy Risk: There is a risk of over-collection of information for making a benefit
determination.
Mitigation: The USCIS Office of Privacy reviews each immigration form during the form
development process and/or promulgation process to ensure that only the minimum amount of
information is collected to determine benefit eligibility. Furthermore, all data elements collected are
negotiated with and approved by OMB during PRA collection review.
USCIS designed CLAIMS 3 specifically to collect and store only the information that is
necessary to adjudicate the benefit request forms processed by USCIS. USCIS requires the information
collected and stored in CLAIMS 3 to establish the identity of the benefit requestor or beneficiary and to
process the benefit request to determine benefit eligibility.
Privacy Risk: There is a risk that information in CLAIMS 3 is replicated and shared via
eCISCOR and therefore may be inaccurate.
Mitigation: This risk cannot be mitigated. USCIS uses eCISCOR to share CLAIMS 3
information more efficiently with other USCIS systems for interoperability purposes. If constant queries
were performed against CLAIMS 3, which is a live transaction system designed to perform real-time
daily tasks for USCIS customers, the primary source system functionality would significantly decrease.
unsurpassable standards of professionalism and ethical conduct. The BASIC curriculum covers public service, immigration
law, customer service, fraud and national security, and other topics to ready new immigration officers for the task of
ensuring the right benefit to the right person at the right time.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 18

The CLAIMS 3 system lag would cause considerable mission disruption. Therefore, USCIS relies on
the eCISCOR system to perform queries. To mitigate the risk of inaccurate data within eCISCOR,
eCISCOR refreshes from CLAIMS 3 and other source systems on a daily basis (generally overnight). A
daily refresh is the most frequent timeframe for refresh that USCIS can implement without impacting
the functionality of the live transaction source systems.

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.

USCIS uses CLAIMS 3 and its associated systems to support and manage the administration and
adjudication of certain benefit requests. Specific uses of CLAIMS 3 and the information it contains
include:
•

Identify missing information and make requests for additional information;

•

Provide a repository of data to assist with future immigration benefit requests;

•

Schedule interview and biometrics appointments;

•

Facilitate and maintain security screening check results to determine suitability for immigration
benefits using criminal, immigration, or terrorism-related history;

•

Generate and issue notices;

•

Provide data necessary to assist in the determination of immigration and employment status to
support the Verification Program;

•

Manage adjudicative workflow;

•

Share information with internal and external partners for mission-related activities; and,

•

Generate reports.

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.

No.

3.3

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

Yes. DHS Components have read-only access to CLAIMS 3 to perform mission requirements.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 19

CBP uses CLAIMS 3 border enforcement purposes. ICE uses CLAIMS 3 for immigration investigation
purposes. Intelligence and Analysis (I&A) analysts may access CLAIMS 3 for national security
purposes. The Citizenship and Immigration Services Ombudsman’s Office uses CLAIMS 3 for its
USCIS oversight responsibilities.

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that authorized users could use the data for purposes inconsistent
with the original collection.
Mitigation: To ensure the information is used consistently with the purposes of the original
collection, USCIS administrators monitor internal and external user logs to ensure users are only
accessing information related to their job functions. Prior to accessing CLAIMS 3, each user must sign
a user access agreement that outlines the appropriate rules of behavior tailored to CLAIMS 3. USCIS
implements disciplinary rules as a means to govern the use of the system. USCIS reminds employees
accessing the system that the system may be monitored for improper use and illicit activity, and the
penalties for non-compliance, through a warning banner that reiterates the appropriate uses of the system.
All user actions are tracked via audit logs to identify audit information by user identification, network
terminal identification, date, time, and data accessed. This acts as a deterrent to unauthorized activity.
Additionally, all USCIS employees are required to complete role-based and adjudicator training prior to
accessing CLAIMS 3.
Privacy Risk: There is a risk that unauthorized users may gain access to CLAIMS 3.
Mitigation: All records are protected from unauthorized access through appropriate
administrative, physical, and technical safeguards such as restricting access to authorized personnel who
have a need-to-know. CLAIMS 3 is a web-based application that is only available through the DHS
USCIS network. Access to CLAIMS 3 is granted to only a limited number of users for mission-related
purposes. Access is granted based on the user’s job function (i.e., receipting, clerk, adjudicator) and
physical location (i.e., Vermont, Texas, Nebraska, California, Virginia, or field offices). CLAIMS 3
users must have access to the USCIS network and have USCIS credentials.
Authorized employees must use their issued credentials, also known as PIV cards, to access
CLAIMS 3. Employees, who do not require access to CLAIMS 3, will not be able to access CLAIMS 3
with their PIV card. Access to the system via PIV card is consistent with the National Institute of
Standards and Technology 800-63 Level 4-assurance of the user’s identity. 52 Finally, USCIS deploys
user logs to ensure users are only accessing information related to their job functions.

See NIST Special Publication (SP) 800-63-2, Electronic Authentication Guideline, dated August 2013, available at
http://csrc.nist.gov/publications/nistpubs/800-63-1/SP-800-63-1.pdf.
52

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 20

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.

Each benefit request form contains a Privacy Act Statement that provides notice to individuals
about the collection, USCIS’s authority to collect information, the purposes of data collection, routine
uses of the information, and the consequences of declining to provide the requested information to
USCIS. The forms also contain a provision by which an applicant authorizes USCIS to release any
information received from the benefit requestor or beneficiary as needed to determine eligibility for
benefits. Additionally, individuals receive general notice through this PIA, DHS/USCIS/ICE/CBP-001
Alien File, Index, and National File Tracking SORN, DHS/USCIS-002 Background Check Service
SORN, and the DHS/USCIS-007 Benefits Information System SORN.

4.2

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

By submitting benefit request forms to USCIS, applicants have consented to USCIS use of the
information submitted for adjudication purposes. Applicants who apply for USCIS benefits have an
opportunity and ability to decline to provide information. USCIS benefit applications require the
applicant to provide biographic and/or biometric information. This information is critical in making an
informed adjudication decision to grant or deny a USCIS benefit. Failure to submit such information
may prohibit USCIS from processing and properly adjudicating the application and thus precludes the
applicant from receiving the benefit.

4.3

Privacy Impact Analysis: Related to Notice

There is no privacy risk associated with notice because all information is provided voluntarily
and USCIS provides notice to individuals through a Privacy Act Statement, this PIA, and the associated
SORNs.

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 is working with NARA to update and consolidate the current retention schedules: N1563-04-03 and N1-566-08-12. Under the proposed update retention schedule for CLAIMS 3, the system

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 21

will retain records 50 years from the date of the last completed action. This retention schedule allows
USCIS to address any follow-up inquiries or requests related to the application, including inquiries
related to security and FOIA/PA matters.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: USCIS’s extension of the retention period from 15 years to 50 years creates a risk
of retaining the data for longer than necessary, which may lead to stale or inaccurate data.
Mitigation: USCIS retains CLAIMS 3 data to maintain a complete and accurate history of an
individual’s immigration interaction with USCIS for future benefit requests. This expanded retention
schedule allows USCIS to address any follow-up inquiries or requests related to the application,
including inquiries related to law enforcement, public safety, national security, and to FOIA/PA matters.
Expanding the records retentions schedule allows for USCIS to provide as much information as
permitted to the individual regarding his or her immigration history.
The purpose of maintaining the information in CLAIMS 3 for such a long retention period is to
provide a complete history of an individual’s immigration benefit history with USCIS. USCIS continues
to update CLAIMS 3 as individuals continue to file immigration benefits with the agency – ensuring that
the information is accurate and complete while maintaining a historical record of interactions with
USCIS and benefit status changes.

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.

USCIS shares information from CLAIMS 3 with other federal agencies for the purpose of
processing applications or petitions for benefits under the INA. USCIS may also share information with
federal, state, local, and foreign government agencies and authorized organizations in accordance with
approved routine uses, as described in the associated published system of records notices.
Department of State (DOS)
USCIS and DOS are partners in the processing of immigration benefit cases. 53 DOS has readonly access to a subset of CLAIMS 3 data. Access to CLAIMS 3 provides DOS consular officers with
53

Memorandum of Agreement between the Department of State and the Department of Homeland Security regarding the

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 22

information on USCIS adjudications of benefits and other decisions relating to non-immigrant and
immigrant visas and naturalization cases. This includes data on pending benefit request forms, as well
as historical information. This data sharing arrangement allows USCIS and DHS to increase processing
efficiency and maintain a comprehensive picture of a benefit requestors’ status from visa application to
naturalization. It will reduce the likelihood that an individual or group might obtain an immigration
benefit under the INA through fraud or error.
Department of Labor (DOL)
USCIS is responsible for determining if a foreign national sought by an employer to work on a
temporary or permanent basis in the United States has the necessary qualifications and meets the
requirements for the immigration classification. For most employment-based categories (non-immigrant
and immigrant) there is a labor component that must be satisfied by employers before they may hire a
foreign worker. 54 DOL is responsible for enforcement of labor certification violations and violations of
U.S. labor laws. DOL has the ability to sanction employers that fail to comply with those laws and DHS
has the authority to bar employers form seeking to bring additional foreign laborers to the United States
if they have been found to be violators by DOL. To determine employer violations, DOL reviews what
employers are actually doing once the foreign worker is employed versus what they promised to do/or
claimed they did at the certification/petition stage.
USCIS provides DOL access to the Person Centric Query System (PCQS) 55 to view, on a readonly basis, data drawn from CLAIMS 3 that contain employment-based non-immigrant and immigrant
petition data and DOL will provide USCIS data from its Permanent Labor Certification (PERM) system
and iCERT system from the permanent and temporary labor certifications and non-immigrant labor
condition applications submitted by employers for DOL approval.
Selective Service System (SSS)
The SSS is an independent federal agency that is responsible for ensuring emergency military
manpower needs pursuant to the Military Selective Service Act. 56 USCIS provides immigrant adjustment
of status and visa information on aliens subject to military conscription to SSS. SSS does not have a
direct access with the CLAIMS 3 system. On a monthly basis, CLAIMS 3 provides SSS with a manually-

sharing of visa and passport records and immigration and naturalization and citizenship records, signed November 18,
2008.
54
This is done through filing of a labor certification (nonimmigrant and immigrant petitions) or a labor condition
application (LCA) (nonimmigrant) with DOL. Before employers can import foreign labor they must agree to comply with
certain U.S. laws re: paying the prevailing wage, complying with required working conditions, testing the labor market for
U.S. workers, etc.
55
See DHS/USCIS/PIA-010 - Person Centric Query Service, available at www.dhs.gov/privacy.
56
50 U.S.C. App. 451 et seq.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 23

extracted file of adjustment of status and immigrant visa information for eligible aliens. This file is sent
via encrypted email from USCIS to SSS. No data is sent from the SSS to USCIS/CLAIMS 3.
Social Security Administration (SSA)
USCIS, DOS, and the SSA currently have a Memorandum of Understanding (MOU) in place
that covers the process in which SSA works with USCIS to issue SSNs and Social Security cards for
immigrants through a process called Enumeration at Entry (EAE). 57 As part of the DOS immigrant visa
application process, immigrants outside the United States have the option to apply for an SSN card at
the same time they apply for an immigrant visa. Once DOS approves their visa application and DHS
admits them into the United States for permanent residence, SSA automatically issues the SSN card.
USCIS electronically transmits to SSA enumeration data for resident aliens with employment
authorization who request a SSN or replacement Social Security card. This process will allow USCIS
benefit seekers to request a SSN or replacement card as part of the USCIS benefit process.

6.2

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

DOS
Sharing USCIS data with DOS is compatible with the purpose of the system because the DOS
mission, like USCIS, includes ensuring lawful visits and immigration to the United States as dictated by
the INA. Routine Use I of the BIS SORN permits USCIS to share information with the DOS for the
purpose of assisting in the processing of benefit requests under the INA, and all other immigration and
nationality laws including treaties and reciprocal agreements.
DOL
Sharing USCIS data with DOL is compatible with the purpose of the system because the
respective missions are responsible for administering and enforcing the INA and other relevant
immigration laws. Routine Use X of the BIS SORN permits USCIS to share information with the DOL
of enforcing labor certification violations and violations of U.S. labor laws.
SSS
Sharing USCIS data with SSS is compatible with the purpose of the system because Section
453(a) of the Military Selective Service Act requires every male citizen of the United States, and every
other male person residing in the United States, who is between the ages of 18 and 26, to present his self
for and submit to registration. Routine Use Q of the BIS SORN permits USCIS to share information
57
Memorandum of Understanding between Social Security Administration and Immigration and Naturalization
Service (MOU), dated December 18, 2000. The party noted as the Immigration and Naturalization Service is now known as
U.S. Citizenship and Immigration Services (USCIS). Provisions included in and addressed by the MOU are still applicable
today.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 24

with SSS to verify or ascertain the citizenship or immigration status of any individual within the
jurisdiction of the agency for any purpose authorized by law.
SSA
Sharing USCIS data with SSA is compatible with the purpose of the system because Sections
205(b)(2) of the Social Security Act, as amended, authorizes SSA to issue a Social Security card to aliens
at the time of their lawful admission to the United States. Routine Use R of the BIS SORN permits
USCIS to share information with the SSA for the purpose of issuing a Social Security number and card
to an alien who has made a request for a Social Security number as part of the immigration process and
in accordance with any related agreements in effect between the SSA, the DHS and the DOL entered
into pursuant to 20 CFR 422.103(b)(3); 422.103(c); and 422.106(a), or other relevant laws and
regulations.

6.3

Does the project place limitations on re-dissemination?

Yes. DHS or USCIS enters into Memoranda of Understanding/Agreement (MOU/A) with
external organizations prior to the systematic sharing of information. When sharing information with
parties outside of DHS, the same specifications related to security and safeguarding of privacy-sensitive
information that are in place for USCIS and DHS are applied to the outside entity. The agreements
between DHS and external entities (e.g., DOL, DOS, SSS, and SSA) fully outline responsibilities of the
parties, security standards, and limits of use of the information, including re-dissemination, prior to
information sharing. Access to records is governed by need-to-know criteria that demand the receiving
entity demonstrate the mission-related need for the data before access is granted. In the terms of a
negotiated agreement or the language of an authorization providing information to an external agency,
USCIS includes justification for collecting the data, and an acknowledgement that the receiving agency
will not share the information without USCIS or DHS’s permission, as applicable.

6.4

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

USCIS keeps an electronic record of all CLAIMS 3 records sent to non-DHS partners.
Furthermore, USCIS updates individual CLAIMS 3 case records to reflect that a specific check has been
completed.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk that data shared by USCIS with external partners will be used
beyond the original purpose of collection (immigration benefits).
Mitigation: USCIS is careful to share data with external agencies that have a need to know and
put the information to a use that is compatible with USCIS SORNs. USCIS documents these safeguards
in MOU/MOA with the external partners. All prospective information handlers must be authorized to

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 25

access the information. This mitigates the risk of unauthorized disclosure by requiring a trained
employee with access to the information to review the information before sharing the information with
an external agency.
Privacy Risk: There is a risk that USCIS may disclose protected information inconsistent with
the confidentiality requirements of 8 U.S.C. § 1367.
Mitigation: DHS employees are aware of the importance of safeguarding information protected
by 8 U.S.C. § 1367. In addition, DHS issued a new Management Directive and Instruction to remind all
DHS officers and employees they are generally prohibited from permitting use by or disclosure to anyone
other than a sworn officer or employee of DHS, the DOS, or the Department of Justice (DOJ) of any
information relating to a beneficiary of a pending or approved application for victim-based immigration
benefits. 58
Prior to disclosing any information USCIS employees are required to verify the status of an
individual. USCIS enhanced the Central Index System to tag records relating to a protected individual
and that specific procedures regarding the disclosure and use apply to users accessing the information.
CIS includes an alert message to indicate that an individual is protected by 8 U.S.C. § 1367. The message
reads: 8 USC 1367 Protected Information–Disclosure and Use Restrictions Apply. The statutory
confidentiality protections at 8 U.S.C. § 1367 generally prohibit the disclosure or use of any information
about applicants for, and beneficiaries of, certain victim-based immigration benefits, including T
nonimmigrant status, U nonimmigrant status, or relief under the Violence Against Women Act (VAWA).
Applicants for, and beneficiaries of, these benefits are those people who have been victimized by others,
including human traffickers, criminal gangs, or abusive spouses. Beneficiaries may also include
qualifying family members (derivatives) of the victim.
The law requires that USCIS protect information about principal applicants and their derivatives
from disclosure in order to avoid endangering the victims by providing their victimizers any personal
information about them. These confidentiality protections generally continue indefinitely; they may
terminate only when the application for relief is denied and all opportunities for appeal of the denial have
been exhausted. Any record in CIS that displays this banner must be handled as Section 1367 Information
in accordance with USCIS policy

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, and/or filing complaints.

DHS Management Directive 002-02 Implementation of Section 1367 Information Provisions (November 1, 2013) and
corresponding Instruction 002-02-001.
58

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 26

7.1

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

An individual may gain access to his or her USCIS records by filing a FOIA/PA request. If an
individual would like to file a FOIA/PA request to view his or her USCIS record, he or she may mail the
request to the following address:
National Records Center
Freedom of Information Act (FOIA)/Privacy Act Program
P.O. Box 648010
Lee’s Summit, MO 64064-8010
Further information about FOIA/PA requests for USCIS records is available at http://www.uscis.gov.

7.2

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

Individuals should submit requests to contest or amend information as discussed in Section 7.1.
The requestor should clearly and concisely state the information being contested, the reason for
contesting or amending it, and the proposed amendment. The requestor should also clearly mark the
envelope, “Privacy Act Amendment Request.” The record must be identified in the same manner as
described for making a request for access.

7.3

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

USCIS notifies individuals of the procedures for correcting their information in this PIA, Privacy
Act Statements, and the USCIS website. Specifically, the SORNs set forth in Section 1.2 provide
individuals with guidance regarding the procedures for correcting information. The Privacy Act
Statements, including notice of an individual’s right to correct information, are also contained on the
instructions to immigration forms published by USCIS.

7.4

Privacy Impact Analysis: Related to Redress

There is no risk associated with redress in relation to CLAIMS 3. USCIS provides individuals
with access to his or her records in CLAIMS 3 when requested through a FOIA/PA request. The
information requested may be exempt from disclosure under the Privacy Act because information
contained within CLAIMS 3 may contain law enforcement sensitive information, the release of which
could possibly compromise ongoing criminal investigations.

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

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 27

8.1

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

USCIS ensures that practices stated in this PIA comply with internal USCIS policies, including
the USCIS privacy policies, SOPs, information sharing agreements, orientation and training, rules of
behavior, and auditing and accountability.
CLAIMS 3 has an audit trail capability to monitor user activities and generate alerts for
unauthorized access attempts. The general audit log and the security log allow the Global Administrator
to select event type, such as access or logon, and the data displayed includes timestamp, name, IP,
transaction, and site. The other log is the auto lock log and the display for it shows the employee’s name,
last login, auto lock date with time, reinstate date with time, username, and site. This auditing is a strong
influence for users to use CLAIMS 3 appropriately.

8.2

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

USCIS employees and contractors are required to complete annual Privacy and Computer
Security Awareness Training to ensure their understanding of proper handling and securing of PII.
Privacy training addresses appropriate privacy concerns, including Privacy Act obligations (e.g.,
SORNs, Privacy Act Statements). The Computer Security Awareness Training examines appropriate
technical, physical, and administrative control measures. Leadership at each USCIS office is responsible
for ensuring that all federal employees and contractors receive the required annual Computer Security
Awareness Training and Privacy training.

8.3

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

USCIS deploys user role-based access controls and enforces a separation of duties to limit access
to only those individuals who have a need-to-know in order to perform their duties. Each operational
role is mapped to the set of system authorizations required to support the intended duties of the role. The
mapping of roles to associated authorizations enhances adherence to the principle of least privilege.
Authorized users are broken into specific classes with specific access rights. This need-to-know is
determined by the respective responsibilities of the employee. These are enforced through DHS and
USCIS access request forms and procedures.

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?

USCIS has a formal review and approval process in place for new sharing agreements. Any new
use of information or new access requests for the system must go through the USCIS Change Control

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 28

Process and must be approved by the proper authorities of this process, such as the USCIS Privacy
Officer, Chief of Information Security Officer, Office of Chief Counsel, and the respective Program
Office.

Responsible Officials
Donald K. Hawkins
Privacy Officer
U.S. 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

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 29

Appendix A

USCIS Immigration Forms and Associated OMB Control Numbers processed in CLAIMS 3
Form Name and Number

OMB Control Number

Paper
Filing

EOIR-26, Notice of Appeal from Decision of
Immigration Judge

1125-0002

X

EOIR-29, Notice of Appeal from Decision of
District Director

1125-0010

X

I-102, Application for Replacement/Initial
Nonimmigrant Arrival-Departure
Document

1615-0079

X

I-129, Petition for Nonimmigrant Worker

1615-0009

X

I-129B, Petition for Nonimmigrant Worker

1615-0009

X

I-129BF, Petition for Nonimmigrant
Worker: FTA

1615-0009

X

I-129CW, Petition for CNMI-Only
Nonimmigrant Transition Worker

1615-0111

X

I-129F, Petition for Alien Fiancé(e)

1615-0001

X

I-129H, Petition for Nonimmigrant
Worker: H-1, H-2, or H-3

1615-0009

X

I-129HF, Petition for Nonimmigrant
Worker: H-1, H-2, or H-3 - FTA

1615-0009

X

I-129L, Petition to Employ Intra-Company
Transferee

1615-0009

X

I-129LF, Petition to Employ Intra-Company
Transferee FTA

1615-0009

X

I-129S, Nonimmigrant Petition Based on
Blanket L Petition

1615-0010

X

I-130, Petition for Alien Relative

1615-0012

X

I-130O, Immigrant Petition for Relative

1615-0012

X

Electronic
Filing

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 30

I-130S, Visa Petition for Spouse

1615-0012

X

I-131 , Application for Travel Document

1615-0013

X

I-131B, Effective Date for I131 Advanced
Parole Approvals Sent to ICPS

1615-0013

X

I-140, Immigrant Petition for Alien
Workers

1615-0015

X

I-191, Application for Advance Permission
to Return to Unrelinquished Domicile

1615-0016

X

I-192, Application for Advance Permission
to Enter as Nonimmigrant

1615-0017

X

I-193, Application for waiver of Passport
and/or Visa

1651-0107

X

I-212, Application for Permission to
Reapply for Admission into the U.S. after
Deportation or Removal

1615-0018

X

I-246, Application for Stay of Deportation

1653-0021

X

I-290A, Appeal, Motion to Reopen or
Reconsider

1615-0095

X

I-290AA, Notice of Appeal to the Board of
Immigration Appeals

1615-0095

X

I-290AP, Notice of Appeal to the Board of
Immigration Appeals

1615-0095

X

I-290B, Notice of Appeal to the
Administration

1615-0095

X

I-290C, Certified Appeal, Motion to Reopen
or Reconsider

1615-0095

X

I-290M, Motion to Reopen or Reconsider

1615-0095

X

I-352, Immigration Bond

1653-0022

X

I-360, Petition for Amerasian, Widower or
Special Immigrant

1615-0020

X

I-407, Record of Abandonment of Lawful

1615-0130

X

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 31

Permanent Resident Status
I-485, Application to Register Permanent
Residence or Adjust Status and
Supplement A to Form I-485

1615-0023

X

I-485 Supplement A, Adjustment of Status
Under Section 245(i)

1615-0023

X

I-485 Supplement B, NACARA Supplement
to Form I-485 Instructions

1115-0221

X

I-485C, HRIFA Supplement to Form I-485

1615-0024

X

I-485 Supplement E, Instructions for I-485,
Supplement E

1615-0023

X

I-515, Deficiency Notice to Arriving F-1, M1, or J-1

1615-0003

X

I-526, Immigrant Petition by Alien
Entrepreneur

1615-0026

X

I-526O, Request Determination that
Prospective Immigrant Is an Investor

1615-0026

X

I-539, Application to Extend/Change
Nonimmigrant Status

1615-0003

X

X

I-539O, Application to Extend Temporary
Stay

1615-0003

X

X

I-539PP, Premium Processing

1615-0003

X

X

I-566, Inter-Agency Record of Individual
requesting Change/Adj. To or from A or G
Status

1615-0027

X

I-600, Petition to Classify Orphan as an
Immediate Relative

1615-0028

X

I-600A, Application for Advance
Processing of Orphan Petition

1615-0028

X

I-601, Application for Waiver of Grounds of
Inadmissibility

1615-0029

X

I-601A, Application for Provisional

1615-0123

X

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 32

Unlawful Presence Waiver
I-612, Application for Waiver of Foreign
Residence Requirement of Sec. 212(e) of
the INA

1615-0030

X

I-643, HHS Statistical Data for
Refugee/Asylee Adjusting Status

16150070

X

I-687, Application for Status as a
Temporary Resident under Sec. 245A of
the INA

1615-0090

X

I-690, Application for Waiver of Grounds of
Inadmissibility

1615-0032

X

I-694, Notice of Appeal of Decision

1615-0034

X

I-695, Application for Replacement of
Form I-688a or I-688

1615-0034

X

I-698, Application to Adjust Status from
Temporary to Permanent Resident

1615-0035

X

I-730, Refugee/Asylee Relative Petition

1615-0037

X

I-751, Petition to Remove Conditions on
Residence

1615-0038

X

I-765, I-765WS, Application for
Employment Authorization

1615-0040

X

I-765V, Application for Employment
Authorization for Abused Nonimmigrant
Spouse

1615-0040

X

I-817, Application for Family Unity

1615-0005

X

I-821, Application for Temporary
Protected Status

1615-0043

X

I-821D, Consideration of Deferred Action
for Childhood Arrivals

1615-0124

X

I-824, Application for Action on an
Approved Application or Petition

1615-0044

X

I-829, Petition by Entrepreneur to Remove

1615-0045

X

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 33

Conditions
I-864, Affidavit of Support under Section
213A of the Act and Notification of
Reimbursement of Means-Tested Benefits

1615-0075

X

I-864A, Contract between Sponsor and
Household Member

1615-0075

X

I-864EZ, Affidavit of Support Under Section
213A of the Act

1615-0075

X

I-864W, Intending Immigrant’s Affidavit of
Support Exemption

1615-0075

X

I-865, Sponsor's Notice of Change of
Address

1615-0076

X

I-905, Application for Authorization to
Issue Certification for Health Care Workers

X

I-907, Request for Premium Processing
Service

1615-0048

X

I-912, Request for Fee Waiver

1615-0116

X

I-914, Application for T Nonimmigrant
Status; Application for Immediate Family
Member of T-1 Recipient; and Declaration
of Law Enforcement Officer for Victim of
Trafficking in Persons

1615-0099

X

Form I-914, Supplement A, Application for
Immediate Family Member of T-1
Recipient

1615-0099

X

Form I-914, Supplement B, Declaration of
Law Enforcement Officer for Victim of
Trafficking in Persons

1615-0099

X

I-918, Application for U Nonimmigrant
Status Application for U Nonimmigrant
Status; Application for Immediate Family
Member of U-1 Recipient; and U
Nonimmigrant Status Certification

1615-0104

X

Form I-918, Supplement A, Petition for
Qualifying Family Member of U-1 Recipient

1615-0104

X

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 34

Form I-918, Supplement B, U
Nonimmigrant Status Certification

1615-0104

X

I-929, Petition for Qualifying Family
Member of a U-1 Nonimmigrant

1615-0106

X

N-470,* Application to Preserve Residence
for Naturalization

1615-0056

X

N-644,* Application for Posthumous
Citizenship

1615-0059

X

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 35

Appendix B

Tools and methods used to prioritize cases

USCIS offices use various tools and methods to prioritize cases for review. This includes:
California Service Center (CSC)
•

The Center Activity Tracking System (CATS) is used to report on the activities and productivity of
the CSC. The system operates by allowing employees to track their work activities and production
over the course of a day.
o The Premium Processing Alert (PP Alert) provides a reminder email to the adjudicator
assigned to a file as well as his or her supervisor. Noting that the premium processing files
are to be adjudicated in 15 days or less, an email alert is sent to the officer and supervisor
starting on the 10th day and continues until the file has a final adjudicative decision. The
application provides the receipt number, officer assigned, officer’s supervisor, NFTS
location, and telephone number.

Texas Service Center
•

The Correspondence Handling and Management Planning System (CHAMPS) uses CLAIMS 3 data
extracts to manage and monitor case workloads. CHAMPS provides reporting capabilities to identify
‘ready to work’ cases and to track cases throughout the adjudication process. 59

Vermont Service Center
• In order to track pending cases, a designated VSC employee runs a query of CLAIMS 3 replicated
data from the VSC servers to identify cases that are 15 days old and notifies the adjudicator assigned
to the case.
Nebraska Service Center
•
•

Using SMART, adjudicators pull information from CLAIMS 3 to identify what cases are still
pending on “X” day and then locates the file using NFTS.
A large portion of cases adjudicated at the NSC are Employment-Based Filings. To efficiently
manage Employment-Based Filings the NSC created a locally – developed application, known as the
EB Database. The EB Database is used daily by the NSC to identify and efficiently account for
principal applicants and their dependent family members. These Employment-Based Filing
applicants must be processed for security checks and prepared for adjudication in a timely manner.

See DHS/USCIS/PIA-012 - Correspondence Handling and Management Planning System (CHAMPS), available at
www.dhs.gov/privacy.
59

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 36

The EB Database also tracks cases that cannot be adjudicated to completion due to unavailability of
visas from the Department of State, and must be pre-adjudicated and held until a visa becomes
available.

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 37

Appendix C

Systems used to support automated adjudication

These systems include, but are not limited to:
•

System Electronic Registration Approval (SERA), used by the CSC, to electronically
organize and review incoming Temporary Protected Status (TPS) re-registration filings.
SERA access TPS re-registration cases from CLAIMS 3, validates each application, and
categorizes cases for automatic approval or manual adjudication. 60

•

Center Adjudication System Electronic Processing (CasePro), used by the Vermont Service
Center, which electronically organizes and reviews incoming TPS, Deferred Enforced
Departure (DED), and Deferred Action for Childhood Arrivals (DACA) filings, identifies
approvable cases, automates the adjudication of some cases which meet filing requirements,
and routes filings requiring additional review to the manual resolution process. 61

These electronic case management systems either retrieve data directly from CLAIMS 3 or eCISCOR.

See DHS/USCIS/PIA-058 System Electronic Registration Approval (SERA), available at www.dhs.gov/privacy.
See DHS/USCIS/PIA-040 Center Adjudication System Electronic Processing (CasePro) available at
www.dhs.gov/privacy.
60
61

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 38

Appendix D

CLAIMS 3 Minor Applications
Application Name

Marriage Fraud
Amendment System
(MFAS)

Function

Type of
Information

Location

PIA

Enterprise-wide

CLAIMS 3 PIA

Enterprise-wide

CLAIMS 3 PIA

Schedules

NBC

CLAIMS 3 PIA

Notices (receipt,
approval, and

CSC, NSC, TSC
and VSC

Benefit Decision
Output

MFAS is a module of CLAIMS 3
MF comprised of an application
and IDMS database. MFAS
supports and maintains casework
for petitions for Legal Permanent
Residency by aliens who have
Case Processing and
previously been granted
Status information
Conditional Permanent Residency
under the terms of the Marriage
Fraud Amendment, including
entrepreneurs. MFAS facilitates the
adjudication and notification
process for this program.

Citizenship and Immigration
Services requires that the Federal
Bureau of Investigation (FBI)
conduct a criminal background
investigation on any alien applying
for immigration benefits. FD-258
MF maintains information on
individual applicants’ fingerprint
Fingerprint Processing
Fingerprint Check
status. Each record contains
Mainframe (FD-258 MF)
Results and Status
applicant information that was sent
to the FBI, such as Name, Birth
Date, and other biographical data,
as well as Date Fingerprinted and
Date Sent to FBI. The records also
contain other information received
from the FBI such as FBI Process
Date and FBI Search Result.

Adjustment of Status
(AOS) Scheduler

The AOS Scheduler provides a
means of managing client
interviews and appointments for
the CLAIMS Benefit systems. It
has two distinct functions that are
supported by a User and a
Processor Version. The User
Version is used to schedule and deschedule interviews at the
workstation. The Processor Version
generates a text file to upload to the
CLAIMS 3 MF and CLAIMS 4.

Automated Premium APPLES is used to create and send
Processing LAN e-mail
e-mail notices to petitioners. It

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 39

System (APPLES)

relies on Premium Processing
information in CLAIMS 3 LAN
System. Three types of notices are
created and sent: a receipt notice,
an approval notice, and a reminder
notice.

BRU Gateway hosts Biometric
Retrieval Unit Interface to BBSS,
Biometric Retrieval
the EFI interface to E-Filing, and
Utility (BRU) Gateway
the ESB interface to Lockboxes for
LIFEAct and FBASI.

reminder)

Host interface

CSC, NBC, NSC,
TSC and VSC

Benefit Decision
Output

Customer Relationship CRIS – Interface replaces the IVRS Case Status updates
Interface that extracts status
CSC, NBC, NSC,
Information System
and associated time
updates
from
CLAIMS
3
LAN
TSC and VSC.
Interface
stamps
System Pervasive database.
(CRIS - Interface)

Family-Based
Adjustment of Status
Interface (FBASI)

FBASI is a system solution that
provides the capability to process
Extensible Markup Language
(XML) files sent by File Transfer
Protocol (FTP) from the Chicago
Lockbox (CLB) FTP server and
transfer the information to the
CLAIMS 3. FBASI provides an
efficient method of transferring Adjustment of status CSC, NBC, NSC, Benefit Intake and
data
Receipt
TSC and VSC
data entered by the Bank into
CLAIMS3 for further processing.
The transfer is a daily process
between the Bank and USCIS that
adheres to strict protocols. This
ensures that data is not re-entered,
which reduces errors.

This subsystem provides for the
management and printing of travelrelated documents. Three standard
USCIS workstations and four
Travel Document
printers are provided. There are six
Printing System (TDPS)
roles for processing travel
documents: Quality Assurance
Analyst, Printer Operators,
Destroyer, Destruction Verifier,
Supervisor, and Administrator.

Travel-related
documents

NSC

Benefit Decision
Output

This subsystem provides for the
Travel Document
management and printing of travelPrinting System-PUSH
related documents. This subsystem
(TDPS-PUSH)
is the Push Facility for TDSP.

Travel-related
documents

NSC

Benefit Decision
Output

Receipt Numbers

CSC, NSC, TSC

Interim IBIS

This subsystem allows the use of

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 40

Receipt Numbers to track all IBIS
Checks. The data is extracted by
importing CLAIMS 3 LAN
extracts into the Interim IBIS
database; it then exports the IBIS
EDITRANS Batches from the
Interim IBIS database to create
BLT inputs using EDITRANS.
To support notice/document
production for the Transformation
Program, by producing physical
documents, i.e., Cards, Travel
Documents or Paper.

and VSC

The 7 EPMS Application Servers
(2 in DC1-Production, 2 in DC1Enterprise Print Manager Staging, 2 in TECC TEST and 1 in Cards and TravelTECC DEV) uses Windows’ built- related documents
Service (EPMS)
in service Task Scheduler to create
a task to run a PowerShell script to
restart the EPMS agents at
midnight each day to retrieve
messages for processing. EPMS
uses the Service Account and allow
Windows Credential Manager to
store the users password encrypted.

Data Center One
(DC-1)

ICMS supports an interim process
Adjudications
for adjudication, building a custom
information,
Web-based interface to the
including final
Interim Case
Computer Link Application
approval or denial National Benefits
Management Solution Information Management System 3
information, for Center (NBC) only
(ICMS)
(CLAIMS 3) Local Area Network
family-based
(LAN) via the USCIS Intranet to
adjustment of status
update cases with information from
applications.
the adjudication decision.
Provides the capability to request
and print Employment
Authorization Document (EAD)
Refugee, Asylum, and
cards for Refugee, Asylum, and
Parole System
Parole System (RAPS) cases by
Employment
importing RAPS data into the
Authorization Document
Computer-Linked Application
(RAPSEAD)
Information Management System
(CLAIMS) Local Area Network
(LAN) database.
Document Services
Management System
(DSMS)

DSMS provides tracking activities
associated with version control,
serialized items that will reduce
costs, and introduce greater
efficiencies to the USCIS printing
supply chain. DSMS does not

RAPS Card
Requests

Inventory

Benefit Decision
Output

CLAIMS 3

Nebraska Service Benefit Decision
Output
Center (NSC) only

Transformation
Engineering
Consolidation
Center (TECC),
Eastern Forms
Center (EFC),

Benefit Decision
Output

Privacy Impact Assessment Update

DHS/PIA/USCIS-016(a) CLAIMS 3
Page 41

transmit or receive any data from
CLAIMS 3 LAN or any of its
subsystems.
I-512 Program

Access query developed to print
Travel Documents which are
mailed to the applicant.

Western Forms
Center (WFC)
Access query and
print Travel
Documents

Nebraska Service
Center

Benefit Decision
Output