Pia 56

Privacy Impact Assessment
for the

USCIS Electronic Immigration System
(USCIS ELIS)
DHS/USCIS/PIA-056(a)
December 3, 2018
Contact Point
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
(202) 272-8030
Reviewing Official
Philip S. Kaplan
Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

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Abstract
U.S. Citizenship and Immigration Services (USCIS) operates the USCIS Electronic
Immigration System (USCIS ELIS). USCIS ELIS was originally developed to serve as a publicfacing electronic filing system supporting the submission of benefit request forms. USCIS ELIS
also served as the internal case management system for USCIS adjudicators to efficiently process
benefit request forms. USCIS ELIS was recently redesigned to exclusively serve as an internal
electronic case management system for electronically filed benefit request forms and certain paper
forms. MyUSCIS Account Experience replaced all aspects of the public-facing USCIS ELIS.1
USCIS is updating and reissuing the USCIS ELIS PIA to discuss the shift from supporting the
public-facing electronic filing system to serving solely as an internal case management system
with new functionalities and system interconnections. This PIA replaces the previously issued
DHS/USCIS/PIA-056 published on May 17, 2016. As USCIS ELIS adds other forms and services,
USCIS will update this PIA and its appendices accordingly.

Overview
USCIS is the component within the Department of Homeland Security (DHS) that oversees
lawful immigration to the United States. In part, the USCIS mission is to provide accurate
information while ensuring the integrity of the U.S. immigration system and adjudicating requests
efficiently and fairly. USCIS receives applications, petitions, and other benefit requests
(collectively referred to as benefit request forms) from individuals seeking immigration and nonimmigration benefits. USCIS has historically received paper-based applications for adjudication
and relied on a complex paper-based process to execute the immigration and naturalization
mission.
USCIS is continuing the current paper-based operations and also steadily transforming to
an electronic, online environment to improve operational efficiency, and improve customer
engagement. Currently, most benefit request forms, including all supporting evidence, are still
submitted in paper format by applicants, petitioners, or requestors (collectively referred to as
benefit requestors), or their legal representatives. In turn, USCIS communicates case information
and issues paper notices to benefit requestors and legal representatives.
USCIS offers an alternate filing method, online filing, to improve the way benefit
requestors and legal representatives apply for and manage immigration benefit requests by shifting
the process from a paper-based system to a secure online case management system. The MyUSCIS
Account Experience offers a personalized, online account for benefit requestors and legal

1

See DHS/USCIS/PIA-071 MyUSCIS Account Experience, available at www.dhs.gov/privacy.

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representatives to electronically file benefit request forms, and replaces all aspects of the publicfacing electronic filing component previously available through USCIS ELIS.
Since the MyUSCIS Account Experience is now the public-facing online filing component,
USCIS ELIS serves as the primary internal case management system for both electronically filed
and paper-based benefit request forms. USCIS ELIS creates person-centric accounts for each
benefit requestor. USCIS will continue to expand available immigration product lines within
USCIS ELIS to support the agency’s modernization initiative of receiving and processing forms
in an electronic environment.
Application Initiation
As described in the Benefit Request and Intake PIA, to begin the benefit request process,
the benefit requestor must complete a USCIS benefit request form.2 Individuals have the option to
complete the benefit request form either by paper or, if available, electronically, through an online
account. Both methods collect the same information and fees. Upon completion, individuals
submit the benefit request form, required supporting documents and filing fee payment, or fee
waiver request, as appropriate. Individuals submit benefit request forms according to the form
instructions. USCIS ELIS receives paper forms through the USCIS Lockbox facilities3 or
electronically from a system interconnection with MyUSCIS.4
Paper Filings
USCIS requires benefit requestors to submit paper benefit request forms to a specified
Lockbox facility. U.S. Lockbox facilities are operated by the U.S. Department of Treasury
(Treasury) and are staffed by financial agents working on behalf of USCIS to receive paper
requests, process payments, and forward the immigration requests as directed by USCIS for further
processing. This contractor manages the intake of paper USCIS benefit request forms and the
collection of associated fees submitted by mail. The Lockbox operates the mechanisms to convert
the submitted information into an electronic format, deposit associated filing fees, generate a
receipt or rejection notices to applicants, and transmit the benefit request information to the USCIS
ELIS system. The contractor does not approve or deny benefit request forms received by the
USCIS Lockbox. The Lockbox scans an image of the benefit request form and supporting
documentation into an electronic format and sends it to USCIS ELIS for ingestion. Depending on
the form type, after the form is ingested into USCIS ELIS, the paper copy may be destroyed.

2

See DHS/USCIS/PIA-061 Benefit Request and Intake Process, available at www.dhs.gov/privacy.
The USCIS Lockbox serves as a collection receptacle for the intake of forms and processing of fees for
immigration benefit request forms. For more information, see www.uscis.gov/lockbox.
4
See DHS/USCIS/PIA-071 MyUSCIS Account Experience, available at www.dhs.gov/privacy.
3

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Once information from the paper filing is received, USCIS ELIS generates a “USCIS
Account Acceptance Notice” and mails the notice through the U.S. Postal Service (USPS) to the
benefit requestor and legal representative, when applicable. This notice contains instructions for
creating an optional USCIS online account and contains a passcode which, if used, can link the
submitted paper submission into the newly created online account.5 By creating this online
account, a benefit requestor who filed paper benefit request forms has the opportunity to log into
his or her MyUSCIS online account to access his or her case information. Online account
capabilities include the ability to check the personalized processing status of the submitted benefit
request, obtain copies of USCIS-issued documents associated with the filing (i.e., appointment
notices and request for evidence), and respond electronically to requests for additional information,
such as Requests for Evidence (RFE).
As a security measure, the passcode sent in the “USCIS Account Acceptance Notice”
expires in 30 days. The benefit requestor, however, may later contact the USCIS National
Customer Service Center (NCSC) to request the generation of a new “USCIS Account Acceptance
Notice” with a new activation passcode.6 Benefit requestors who choose not to activate their online
accounts can continue engaging with USCIS through the existing paper-based process.
Online Filing
Benefit requestors who electronically file their request use the MyUSCIS Account
Experience, which offers a personalized, authenticated, and secured account for benefit requestors
and legal representatives to file benefit forms. MyUSCIS Account Experience replaces all aspects
of the public-facing USCIS ELIS. Through MyUSCIS Account Experience, benefit requestors
and/or legal representatives are able to create a personal profile, securely and electronically file
benefit request forms, access pending case information, and securely communicate with USCIS
personnel.
The electronic filing component of MyUSCIS Account Experience offers an interactive
tool that assists individuals with completing certain immigration benefit request forms or certain
fee payments. The electronic benefit request forms collect the same information as the
corresponding paper forms. To initiate the benefit request completion process, the individual
selects his or her desired form type and enters valid data into all required fields. The account holder
may save, edit, delete, or update information when the form is in draft state. MyUSCIS Account
Experience does not keep copies of previous draft iterations and deletes cases if inactive for 30
days. Prior to the submission of the benefit request form, the account holder has the opportunity
to review the provided information.

5
6

See DHS/USCIS/PIA-071 MyUSCIS Account Experience, available at www.dhs.gov/privacy.
See DHS/USCIS/PIA-054 National Customer Service Center, available at www.dhs.gov/privacy.

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After preparing a benefit request, the individual or his or her representative submits the
benefit request form by electronically signing the form and providing payment directly to the
Department of Treasury through an embedded pay.gov screen.7 MyUSCIS sends the filing to
USCIS ELIS for processing once the payment is accepted. USCIS ELIS has a direct interface with
MyUSCIS Account Experience. While there is no public-facing component of USCIS ELIS, it
continues to serve as an internal electronic case management system that allows USCIS
adjudicators to process benefit requests.
Benefit Request Lifecycle
USCIS ELIS is a person-centric case management system used to track and adjudicate
certain benefit request forms. Once a benefit request form is submitted to USCIS, a series of
processing and adjudication actions occur, such as case receipt and intake, biometric collection
appointment generation, case specific processing and management, automated background check,
interview appointment scheduling, final decision rendering, and production of the proof of benefit.
USCIS benefit request forms generally undergo the following steps: (1) Case Intake; (2)
General Pre-Adjudication Procedures (i.e., identity validation checks); (3) Security Screening
Checks; (4) Case Processing; (5) Interview; (6) Decision Rendering; and (7) Post-Adjudication
Processing. USCIS ELIS supports each of these tasks. For each step in the process, USCIS ELIS
sends case status updates with the latest case status to MyUSCIS Account Experience and Case
Status Online to provide the benefit requestor with the latest status of their benefit filing.8
Initial Intake
Case Creation
Benefit request submissions consist of the specific request forms and supporting
documentation and may originate in an electronic format or be converted to an electronic format
from paper. Upon receipt of a benefit request, USCIS ELIS ingests and stores the benefit request
forms and supplemental evidence submitted through the USCIS Lockbox or MyUSCIS online
account and creates a person-centric case for the benefit request filing. USCIS ELIS then searches,
identifies, and consolidates all previous cases associated with the individual within the system to
present to the adjudicator in a singular and comprehensive view. USCIS ELIS provides
information on the individual’s identity, immigration status, previous immigration benefits
processed in USCIS ELIS, and details and results of previous background identity and security
checks.

Payment information is collected by the Department of Treasury’s Pay.gov system (see Financial Management
Service (FMS) PIA and Revenue Collection Records – Treasury/FMS.017 SORN, 68 FR 5691
8
See DHS/USCIS/PIA-019 Customer Relationship Interface System (CRIS), available at www.dhs.gov/privacy.
7

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When a new case is created, USCIS ELIS interfaces with RAILS (not an acronym)9 to
annotate the applicable Alien File10 content residing in USCIS ELIS. RAILS is an automated filetracking system used to maintain an accurate file inventory and track the physical and electronic
location of immigration files.11 Alien File content in USCIS ELIS may originate in an electronic
format or have been converted to an electronic format from paper. All benefit request forms,
supporting evidence submitted with a benefit request, and system data generated for the case are
electronically maintained in USCIS ELIS as part of the Alien File and serve as part of the official
agency record.
General Pre-Adjudication Procedures
Alien Number Validation
USCIS ELIS then validates the benefit requestor’s Alien Number (A-Number), if
applicable, as the first step of the adjudication process. When benefit requestors list an A-Number
on a benefit request, USCIS ELIS concurrently12 runs an automated comparison of the provided
A-Number against the USCIS Central Index System 2 (CIS 2)13 and Alien Number Validation
Microservice.14 CIS employs a strict, Boolean matching process to the data to determine if there
is a match or no match.15 The A-Number Validation Microservice employs a fuzzy match search
to find a list of candidate matches that account for common errors such as keyboard distance typing
errors, transposition of letters or numbers, and transliteration of foreign names.16 The candidate
9

RAILS is the modernized update to the National File Tracking System. See DHS/USCIS/PIA-032 National File
Tracking System (NFTS) and associated updates, available at www.dhs.gov/privacy.
10
The Alien File, or A-File, is created for aliens seeking immigration benefits (i.e., lawful permanent resident,
naturalization), aliens who illegally entered the United States, or other individuals subject to the provisions of the
Immigration and Nationality Act (INA).
11
The purpose of the A-File is to record an individual's immigration applications, petitions, and requests, as well as
enforcement transactions as he or she interacts with the U.S. immigration system. The content in the A-Files consist
of paper and electronic records of the individual's immigration transactions, which may include records of
immigration benefit requests, requests for agency action, and adjudication outcomes.
12
Currently, USCIS is running two A-number validation services. USCIS continues to evaluate use of the ANumber Validation Microservice against the CIS results. This comparison serves to identify any output errors and
refine the algorithms used by the microservice to increase the accuracy of this automated A-Number validation tool
when it will serve as the primary A-Number Validation system.
13
See DHS/USCIS/PIA-009(a) Central Index System, available at www.dhs.gov/privacy.
14
See forthcoming DHS/USCIS/PIA-00# Person Centric Identity Management (PCIM), available at
www.dhs.gov/privacy.
15
Boolean Logic is a form of algebra that is centered around three simple words known as Boolean Operators: “Or,”
“And,” and “Not.” At the heart of Boolean Logic is the idea that all values are either true or false. The use of
Boolean Logic allows for the creation of more complex audience definitions, allowing for audiences to be built to a
very specific set of definitions.
16
Fuzzy matching is a method that provides an improved ability to process word-based matching queries to find
matching phrases or sentences from a database. When an exact match is not found for a sentence or phrase, fuzzy
matching can be applied. Fuzzy matching attempts to find a match which, although not a 100 percent match, is
above the threshold matching percentage set by the application. Fuzzy matching is mainly used in computer-assisted
translation and other related applications.

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matches are then scored using a statistical algorithm to determine the confidence score of how
likely the candidate match is the correct match.
USCIS ELIS runs the two automated comparisons of the applicant declared A-Number
against CIS and Alien Number Validation Microservice search results to verify that the A-Number:
(1) exists and is valid, and (2) matches the name and other biographic identifying information (i.e.,
date of birth, country of birth, country of citizenship/nationality, and A-Number) provided by the
individual. These A-Number Validation tools apply the respective matching logic to validate Anumbers provided by individuals filing benefit requests against the primary A-Number on record
for the individual in various USCIS systems, as well as generate a computed confidence score for
the match. The computed score is a percentage of confidence based on matching fields and
characters. Based on thresholds established for these scores, cases either pass or fail the automated
A-Number validation process. The declared A-Number must be an exact match with CIS for the
A-Number Validation microservice to return a success message and for the case to continue to
USCIS ELIS processing with no manual intervention. If the system cannot automatically verify
this information, USCIS ELIS moves the benefit requestor’s request into an electronic work queue
in which the A-Number discrepancy is researched and resolved by a USCIS adjudicator before
proceeding to adjudication.
Screening (Background, Identity, and Security Checks)
Biometric Collections
After the A-Number is validated, USCIS ELIS interfaces with the National Appointment
Scheduling Service (NASS)17 to schedule an Application Support Center (ASC) biometric
collection appointment for the benefit requestor, a requirement for certain requests. USCIS
requires benefit requestors and beneficiaries for certain immigration benefits to submit their
biometrics along with biographic information provided in the benefit request to USCIS for
background, identity, and security checks.
USCIS uses NASS to schedule biometric appointments for the collection of fingerprints,
photographs, and signatures at an ASC. Each scheduling request sent to NASS includes the benefit
requestor’s name, address, and benefit type. NASS uses the information from USCIS ELIS to
schedule a biometric appointment at the ASC location closest to the benefit requestor address of
record. Once scheduled, NASS sends a biometric appointment confirmation notice for generation
and printing to the Enterprise Print Manager Service (EPMS) and Notice Generation System
(NGS).18 Once the notice is generated, a copy of the notice is stored in USCIS ELIS. EPMS
17

See DHS/USCIS/PIA-057 National Appointment Scheduling System, available at www.dhs.gov/privacy.
EPMS and NGS are legacy systems that were specifically developed for notice generation and printing purposes.
NGS only generates notices and EPMS prints the notices and mails these notices directly to the individuals. EPMS
supports the printing of notices, cards, and booklets for USCIS. For additional information see DHS/USCIS/PIA063 Benefit Decision and Output Processes, available at www.dhs.gov/privacy.
18

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generates a physical appointment notice that is mailed to the benefit requestor and the legal
representative.
At the biometric appointment, USCIS electronically captures the benefit requestor’s
fingerprints and declared biographic information that is required to verify the individual’s identity
and ensure that the correct biographic information is associated with the captured biometrics. This
data is associated together and stored in Customer Profile Management System (CPMS), which is
the centralized source of biometric images used for USCIS benefit card and document
production.19
For benefit fillings that require biometric collections, the case in USCIS ELIS cannot move
to the next stage in the process until the ASC appointment is completed, and the ASC Notification
message is sent to USCIS ELIS, confirming that the applicant appeared at the ASC and biometrics
were collected. USCIS is then able to electronically provide various notices of agency action (e.g.,
interview appointment notices, requests for evidence or originals, notices of intent to deny, or final
agency decisions) for a specific case directly to the benefit requestor or legal representative through
his or her MyUSCIS online account. Individuals who do not have an online account can continue
to receive notices from USCIS through the mail.
Background, Identity, and Security Checks
Most individuals submitting benefit request forms 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. USCIS conducts background,
identity, and security checks as part of case processing.
USCIS runs fraud, criminal, and national security background checks against the following
systems:


19

U.S. Customs and Border Protection (CBP) TECS (not an acronym) Name
Check:20 USCIS conducts a mandatory TECS check on all applicants, petitioners, and
beneficiaries. TECS is an automated enforcement and inspection lookout system that
combines information from multiple agencies, databases, and system interfaces to
compile data relating to national security risks, public safety issues, current or past
targets of investigations, and other law enforcement concerns. The system is
maintained by CBP, and is the principal system used by officers at the border to assist
with screening and determinations regarding admissibility of arriving persons. USCIS

See DHS/USCIS/PIA-060 Customer Profile Management Service, available at www.dhs.gov/privacy.
See DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing, available at
www.dhs.gov/privacy.
20

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





21

Fraud Detection and National Security (FDNS) Directorate uses the ATLAS System21
to facilitate the required TECS checks when performing name checks for all cases
processed in USCIS ELIS. The database searches against the Automated Biometric
Identification System (IDENT),22 Federal Bureau of Investigation (FBI) National
Crime Information Center (NCIC), and Terrorist Screening Database.23 ATLAS
provides alerts to FDNS and USCIS Background Check Officers indicating
information that may have an impact on the processing of the petition or application
and may need to be resolved. Information from a case may also be sent to CBP’s
Advanced Targeting System24 as part of a Continuous Immigration Vetting (CIV)
process. These checks are facilitated using the ATLAS system. Results are stored in
the FDNS Data System (FDNS-DS)25 and made available to USCIS ELIS.
FBI Fingerprint Check:26 USCIS ELIS sends 10 fingerprints and related biographic
data to the FBI Next Generation Identification System (NGI) for a criminal background
check. USCIS ELIS receives the FBI criminal background check response (i.e., “NonMatch” or “Match”).
FBI Name Check:27 USCIS ELIS sends name, date of birth, country of birth, and other
biographic data to the FBI Name Check Program. The FBI Name Check is performed
as a part of the National Name Check Program (NNCP). USCIS ELIS receives
responses for the FBI Name Check request. The results will generally indicate whether
the benefit seeker has any pertinent or derogatory information.
Biometric Identity Check:28 USCIS ELIS queries DHS Office of Biometric Identity
Management (OBIM) Automated Biometric Identification System (IDENT) for
biometric identity verification and to conduct background checks. The information sent

See DHS/USCIS/PIA-013-01 Fraud Detection and National Security Directorate, available at
www.dhs.gov/privacy.
22
The Automated Biometric Identification System (IDENT) is the central DHS-wide system for storage and
processing of biometric and associated biographic information for national security; law enforcement; immigration
and border management; intelligence; background investigations for national security positions and certain positions
of public trust; and associated testing, training, management reporting, planning and analysis, or other administrative
uses. See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.
23
See DHS/ALL/PIA-027 DHS Watchlist Service, available at www.dhs.gov/privacy.
24
See DHS/CBP/PIA-006 Automated Targeting System, available at www.dhs.gov/privacy.
25
See DHS-USCIS-PIA-013(a) Fraud Detection and National Security Data System (FDNS-DS), available at
www.dhs.gov/privacy.
26
See DOJ/FBI Next Generation Identification System PIA available at www.fbi.gov/services/recordsmanagement/foipa/privacy-impact-assessments.
27
See DOJ/FBI Name Check PIA available at www.fbi.gov/services/records-management/foipa/privacy-impactassessments.
28
See DHS/NPPD/PIA-002 Automated Biometric Identification System (IDENT), available at
www.dhs.gov/privacy.

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to IDENT includes 10 fingerprints, photo, and biographic information. IDENT creates
a new encounter with a unique Encounter Identification Number (EID), which is a
unique number found in the Identity Verification Tool (IVT)29 along with Fingerprint
Identification Number (FIN).30 IDENT provides information related to previous
encounters stored in IDENT. The information from these encounters will be used in the
adjudication process.
 Port of Entry Check:31 USCIS ELIS queries DHS CBP Arrival and Departure
Information System (ADIS) for date of entry and port of entry.
 Criminal History Check:32 USCIS ELIS queries DHS ICE Enforcement Integrated
Database (EID) for background information related to the requestor. USCIS ELIS
queries EID for information related to the arrest, booking, detention, and removal of
persons encountered during immigration and law enforcement investigations and
operations conducted by ICE and CBP. EID is a DHS shared common database
repository for several DHS law enforcement and homeland security applications.
If the fraud, criminal, and national security background check identifies potential criminal, public
safety, or national security concerns, the matter is referred to another electronic workflow queue
within USCIS ELIS for resolution. USCIS takes specific measures to address and resolve the
presented concerns before adjudicating the benefit request, which may include a referral to the
USCIS FDNS Directorate.
Case Processing
If biometrics are not required, the benefit requestor’s case advances to the adjudication step
immediately following A-Number validation and resolution of any background check results. If
biometrics are required, the benefit requestor’s case advances once USCIS CPMS sends
notification that the benefit requestor has submitted his or her biometrics at the ASC. USCIS ELIS
automatically places the benefit request in an adjudicator work queue after A-Number validation,
completion of the biometric collections and background checks, and return of the background and
security check results have occurred.
The USCIS adjudicator evaluates all data—the information submitted by the benefit
requestor along with the results of the background and security checks—according to existing
standard operating procedures (SOP) that apply to the benefit request form. USCIS adjudicators
may need to review the A-File (if available) to verify the identity and benefit eligibility of the
benefit requestor. Adjudicators are able to view some A-File content in USCIS ELIS. If an
IVT provides the capability to compare an individual’s biometric and biographic information to previous
biometric encounters captured by other agencies within OBIM IDENT.
30
When a biometric is submitted to the OBIM IDENT for an individual and it is his or her first enrollment in
IDENT, a unique identifier is assigned—the Fingerprint Identification Number (FIN).
31
See DHS/CBP/PIA-024 Arrival and Departure Information System (ADIS) available at www.dhs.gov/privacy.
32
See DHS/ICE/PIA-015 Enforcement Integrated Database (EID), available at www.dhs.gov/privacy.
29

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adjudicator requires a physical A-File, the adjudicator can request the file in USCIS ELIS using a
direct interface with RAILS. USCIS ELIS sends the following to RAILS: full name, the primary
tracking number (the alien number (A-Number)), and date of birth. RAILS collects the following
information from USCIS ELIS: adjudicator’s full name, office location, responsible party code
(RPC), which relates to either a system user or file shelf location and the immigration file’s status
(i.e., retired, record-in-use), and the last transaction (i.e., charged-out, received, in-transit).
To assist the adjudicator in verifying information submitted by the requestor, USCIS ELIS
displays information pulled the Person-Centric Query Service (PCQS).33 This information
includes other names, biographic information, contact information, other A-Numbers, and
additional immigration history data that may also be associated with the requestor. Following
existing SOPs, the adjudicator is able to identify which data is correct or relevant and make updates
to USCIS ELIS to record the correct data about the benefit requestor. USCIS ELIS documents all
updates made to data about the requestor.
USCIS also requires supporting documentation (submitted by the requestor) as initial
evidence of a benefit requestor’s eligibility for a benefit. The burden of proof in establishing
eligibility for an immigration benefit rests with the benefit requestor. Each benefit request form
includes specific evidential requirements. When a benefit requestor can establish that certain
primary evidence is unavailable, secondary evidence, also in specific forms, may be provided.
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.
USCIS may issue a Request for Evidence (RFE)34 or Notice of Intent to Deny (NOID)35 if
a benefit requestor or beneficiary fails to submit evidence or provides insufficient evidence to
establish eligibility. USCIS personnel use Enterprise Correspondence Handling Online (ECHO)36
to generate editable notices using templates and standard text such as RFEs and NOIDs. USCIS
ELIS sends the applicant’s name and address to ECHO to create the notices. USCIS ELIS receives
confirmation from ECHO of the notice generation and a PDF copy of the notice is stored in USCIS
ELIS.

33

See DHS/USCIS/PIA-010 Person Centric Query Service (PCQS), available at www.dhs.gov/privacy.
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.
35
A NOID is a formal statement from USCIS that it has determined that the applicant is ineligible for the immigrant
benefit requested. There are a number of circumstances that may lead to a NOID being sent, and 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). Regardless of the reason behind the NOID, USCIS will grant
the applicant an opportunity to overcome this determination and demonstrate that he or she is eligible.
36
See DHS/USCIS/PIA-063 Benefit Decision and Output Processes, available at www.dhs.gov/privacy.
34

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USCIS mails the notices through the U.S. Postal Service to the benefit requestor and/or her
or his representative with instructions on how to respond or appropriate next steps. For benefit
requestors with a USCIS online account, USCIS also uploads notices for storage and retrieval from
their MyUSCIS online account. When a case has a representative of record, USCIS ELIS also
sends the notice to the legal representative MyUSCIS online account.
Interview
A benefit requestor may be required to appear for an interview at a USCIS Field Office.
To schedule an initial interview, USCIS ELIS interfaces with NASS and sends name, address, ANumber, form type, and date/time for the interview appointment. NASS sends the Interview Notice
request to EPMS and NGS where the notices are generated and sent on to printing. A copy of the
notice is sent back to USCIS ELIS and stored. For benefit requestors with a USCIS online account,
USCIS also uploads notices into MyUSCIS online account. When a case has a representative of
record, USCIS ELIS also sends the notice to the legal representative MyUSCIS online account.
All individuals who arrive at a USCIS Field Office for an interview are compared to a
previously captured photograph and two-print fingerprints using a tool called Identity Verification
Tool (IVT).37 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.
Before the start of the interview, USCIS Field Officers may choose to record the interview,
and will then notify benefit requestors that the interview may be recorded and USCIS adjudicators
may use web cameras to digitally record immigration interviews.38 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.
During in-person interviews for cases in USCIS ELIS only, USCIS adjudicators may use
a tablet. At the time of such interaction, USCIS adjudicators may corroborate information declared
by the requestor on a USCIS-issued form (e.g., spelling of a name), collect new information and
data (e.g., signature), and collect and verify responses provided by the individual at the time of the
in-person interaction. The tablet is physically connected to and communicates directly with USCIS

37

See DHS/USCIS/PIA-060 Customer Profile Management System, available at www.dhs.gov/privacy.
8 C.F.R. § 335.2 (c) states that USCIS officers 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.
38

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ELIS through a USCIS computer. The tablet presents USCIS ELIS information allowing the
benefit requestor to:


Review biographical information;



Review and verify any changes to information on the submitted USCIS form;



Provide responses to any questions related to the in-person interview;



Provide a digital or electronic signature when required; and



Certify that reviewed revisions or changes to the information on the USCIS form are
true and correct.

The USCIS adjudicator follows current processes to verify the identity of individuals at an inperson interview or examination. Any individual participating in an in-person interaction with
USCIS may have his or her identity verified pursuant to the current process. The tablet may also
be used to capture and record the officer’s and applicant’s required signatures that are stored in
USCIS ELIS.
Decision Rendering
After all the steps discussed above are complete, USCIS personnel make a final
determination on the benefit request. USCIS personnel may grant, deny, rescind, or revoke an
immigration benefit.39 Case decision actions are tracked and recorded in USCIS ELIS.
Post-Adjudication Processing
If a final decision of approval is reached by the adjudicating officer, USCIS ELIS uses
automated interfaces with existing USCIS IT systems to generate the proof of benefit (such as a
Lawful Permanent Resident card), as applicable. When a proof of benefit must be produced, and
it requires a photograph, the adjudicator is able to obtain the requestor’s facial photograph,
fingerprint, and signature via an interface with CPMS solely for proof of benefit production
purposes. The facial photograph and other biometric elements are temporarily displayed in USCIS
ELIS and can be adjusted to improve image quality for printing. USCIS ELIS allows the user to
zoom, pan, lighten, or darken the photo for card production and then certify for printing. After
successful proof of benefit production is completed, the facial photograph obtained from CPMS is
automatically deleted from USCIS ELIS, and the final adjusted image is stored as part of the
printed card record in CPMS.

39

These processes are carried out outside USCIS ELIS. For more information see DHS/USCIS/PIA-062
Administrative Appeals Office Case Management System, available at www.dhs.gov/privacy.

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Post-Decision Reporting
USCIS uses the information contained in USCIS ELIS to generate a number of statistical
reports to measure and evaluate workload for proper resource allocation. USCIS ELIS interfaces
with the Enterprise Citizenship and Immigrations Services Centralized Operational Repository
(eCISCOR) for reporting, statistical analysis, and adjudicatory purposes.40 eCISCOR
interconnects with other systems like the Standard Management Analysis and Reporting Tool
(SMART) sub-system to create customizable reports.41 SMART uses USCIS ELIS 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.

Section 1.0 Authorities and Other Requirements
1.1

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

The primary legal authority supporting the collection of the information provided to USCIS
is the Immigration Nationality Act (INA).42 Specifically, 8 U.S.C. § 1360 requires a central file of
information for the security and enforcement agencies of the Government of the United States that
contains the names of all aliens admitted or denied admission to the United States and such other
relevant information as required to aid in the proper enforcement of this chapter. The Homeland
Security Act of 200243 and the INA charge the Secretary of Homeland Security with administration
and enforcement of the immigration and naturalization laws. The Secretary of Homeland Security
has delegated duties to USCIS pursuant to DHS Delegation 0150.1. DHS also has promulgated
regulations that permit the collection and processing of applications, petitions, and requests online
entitled, “Immigration Benefits Business Transformation, Increment I;44” and “Immigration
Benefits Business Transformation, Increment I; Correction.45”

40

See DHS/USCIS/PIA-023(a) Enterprise Citizenship and Immigrations Services Centralized Operational
Repository (eCISCOR), available at www.dhs.gov/privacy.
41
See DHS/USCIS/PIA-050 Standard Management Analysis Reporting Tool (SMART), available at
www.dhs.gov/privacy.
42
8 U.S.C. § 1101 (2004) et seq.
43
Pub. L. No.107-296, 116 Stat. 2135 (2002), 6 U.S.C. § 112.
44
76 FR 53764 (Aug. 29, 2011).
45
76 FR 73475, (Nov. 29, 2011).

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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 USCIS ELIS:


DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of
Records46 covers individuals who petition for benefits under the INA, and includes
petitioners, preparers, and attorneys. Information covered includes A-number, name,
address, phone number, email address, Social Security number (SSN), date of birth (DOB),
place of birth (POB), countries of citizenship, family history, employment history, and
marriage certificates.



DHS/USCIS-007 Benefits Information System47 covers individuals who have filed
applications or petitions for immigration benefits under INA and provides coverage for
information collected such as name, SSN, records regarding tax payment and financial
matters, and records regarding employment.



DHS/USCIS-018 Immigration Biometric and Background Check48 covers the
background checks that are performed.

1.3

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

Yes. The USCIS ELIS Security Plan was last updated on December 26, 2017. USCIS ELIS
has been granted an authority to operate (ATO) under the USCIS Ongoing Authorization (OA)
process. OA requires USCIS ELIS to be reviewed on a monthly basis and to maintain its security
and privacy posture in order to retain its ATO.

1.4

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

USCIS ELIS serves as the electronic record used to facilitate and track the adjudication of
certain benefit requests. USCIS has many retention schedules to cover different types of data in
USCIS ELIS, including the A-File, draft and filed forms, and systems.

46

DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556 (Sept.
18, 2017).
47
DHS/USCIS-007 Benefits Information System, 81 FR 72069 (Oct. 19, 2016).
48
DHS/USCIS-018 Immigration Biometric and Background Check, 83 FR 36950 (July 31, 2018).

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Electronic Records
An individual's immigration history may be in the following formats: (1) A paper A-File;
(2) an electronic record in the Enterprise Document Management System (EDMS) or USCIS
Electronic Immigration System; or (3) a combination of paper and electronic records and
supporting documentation. USCIS ELIS maintains certain filed benefit requests with USCIS. All
documentation submitted or created in support of a USCIS benefit request case is maintained in
accordance with USCIS policy and NARA retention schedules after being scanned into USCIS
ELIS. Benefit request forms that were rejected because the form was incomplete and/or not
accompanied by the required signature or fee are maintained for 6 years or less.49 These records
have temporary value because they have little or no research value. All other benefit request forms
and other electronic records in USCIS ELIS are designated as A-File records. A-File records are
permanent, whether hard copy or electronic. These records have permanent value because they
document enduring legal rights and have high potential research value. DHS transfers A-Files to
the custody of NARA for retention for 100 years after the individual’s date of birth.
USCIS ELIS Case Management
ELIS also serves as the case processing, adjudication, and management platform for certain
paper and electronically filed benefit request forms. The case management and adjudication data
in USCIS ELIS is covered by the retention schedule for each form type. USCIS will update
Appendix A to this PIA for each form retention schedules.

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.

Each form processed by USCIS ELIS has an existing OMB control number that covers the
USCIS ELIS collection. An updated list is available in Appendix B of this PIA.

Section 2.0 Characterization of the Information
2.1

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

USCIS ELIS collects:


49

Information that is required to adjudicate specific benefit requests will vary for each
immigration benefit type. A full account of what data is requested for each immigration

Please see Appendix A to view the approved NARA schedules for form types processed in USCIS ELIS.

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benefit type can be viewed by referencing the paper forms associated with each
immigration benefit type in Appendix B. A comprehensive list of USCIS forms and the
respective form instructions are available at www.uscis.gov/forms. USCIS ELIS also
contains information from other USCIS, DHS, and external systems. USCIS ELIS
information includes:
o Full name;
o Aliases;
o Mailing and physical address;
o A-Number;
o SSN (if applicable);
o USCIS Online Account Number;
o Date of birth (DOB);
o Country of birth (COB);
o Immigration status;
o Date permanent resident status became effective;
o Telephone numbers;
o Email address;
o Gender;
o Weight;
o Height;
o Eye color;
o Travel history, as reported by the applicant;
o Education history;
o Employment information; and
o Criminal history information.


E-signature from the requestor, which includes check-box attestation, requestor’s
name, Internet Protocol (IP) address from which the filing is submitted, and time/date
stamp;



Background and security check results about the requestor;

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

Images of the benefit request form and supplemental evidence;50



Case processing information and generated data, such as notices, internal case
processing notes, and decisions;



Social media handles and aliases, associated identifiable information, and publicly
available search results; and



Temporarily stored biometric images, including fingerprints and signature (if not
waived), to allow proper formatting for printing.

2.2

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

Information within USCIS ELIS is obtained from the following sources: (1) benefit
requestors, beneficiaries, accredited representatives, attorneys, form preparers, and/or interpreters,
(2) internal DHS systems, and (3) external systems or sources. Most of the information in USCIS
ELIS is obtained from the data provided by the benefit requestor or beneficiary on the completed
benefit request form and submitted supporting documentation accompanying his or her benefit
request. USCIS ELIS also interconnects with internal or external systems, and USCIS adjudicators
can manually enter information into USCIS ELIS (i.e., interview comments and background
dates). Most background check results are maintained in USCIS ELIS.
USCIS also collects information from publicly available sources, such as general internet
searches of publicly available information including publicly available social media information.
Benefit adjudicators may conduct general internet searches to verify the identity and claim of the
individual. FDNS conducts social media searches to verify information provided by the requestor
to investigate indications of fraudulent behavior and identify any threat to public safety or nexus
to known or suspected terrorists during the processing of the requestor’s benefit request. The
results of the general and social media searches are used to verify information relating to the benefit
request, information indicating potential fraud (such as identity fraud or document fraud), or
information regarding criminal activity or national security concerns that would impact eligibility
and admissibility.51 USCIS may only look at publicly available information, and will respect
individuals’ privacy settings. In compliance with DHS Directive 110-01, Privacy Policy for
Operational Use of Social Media and Instruction 110-01-001,52 authorized FDNS personnel are
50

Many USCIS forms require the submission of supplemental forms to establish eligibility for the benefit. Examples
of supplemental evidence may include, but are 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.
51
Information collected from social media, by itself, will not be a basis to deny an immigration benefit request.
52
See DHS Directive 110-01, Privacy Policy for Operational Use of Social Media and Instruction 110-01-001,

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permitted to access social media sites when conducting background checks or administrative
investigations only after they have completed initial USCIS Privacy Requirements for the
Operational Use of Social Media training and program-specific training on the authorized use of
social media, and have signed the “Rules of Behavior” form.53 Authorized USCIS personnel must
complete refresher training and sign the Rules of Behavior annually. When social media is
collected on a benefit requestor the records become part of the USCIS ELIS adjudication and are
retained for the life of the benefit request form as A-File content.

2.3

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

Yes. USCIS ELIS maintains publicly available data from general internet searches used as
part of the benefit adjudication process by adjudicators, and social media postings54 that are used
by authorized FDNS personnel trained to conduct social media reviews. FDNS uses social media
postings to verify information provided by the requestor to investigate indications of fraudulent
behavior and identify any threat to public safety or nexus to known or suspected terrorists in the
processing of the requestor’s benefit request. The social media postings collected on a benefit
requestor become part of the USCIS ELIS adjudication and are retained for the life of the benefit
request form as A-File content.
USCIS only collects social media information that is reasonably related to matters under
USCIS consideration. Social media may be part of the background check process for certain
immigration benefit requests, and background checks are run by USCIS only where USCIS has
the legal authority to do so. This policy permits specifically trained USCIS officers to access
publicly available social media as an aid in determining whether an individual is eligible for an
immigration benefit.

2.4

Discuss how accuracy of the data is ensured.

USCIS ELIS ensures data accuracy primarily by using data entered directly by the
requestor whenever possible. All requests filed using the USCIS online accounts are completed
directly by the benefit requestor except for those accounts set up by a legal representative. Benefit
available at https://www.dhs.gov/policy. This Directive sets privacy policy and requirements for DHS and its
components for the access, collection, use, maintenance, retention, disclosure, deletion, and destruction of PII in
relation to operational use of social media.
53
Select USCIS personnel who seek to access, process, store, receive, or transmit PII obtained through the
Operational Use of Social Media while conducting investigations or background checks are required to complete a
Rules of Behavior (ROB) for the Operational Use of Social Media. These ROBs ensure that users are accountable
for their actions on social media, are properly trained, and aware of the authorized use of social media sites.
54
Privacy update regarding social media use can be found at https://www.uscis.gov/about-us/directorates-andprogram-offices/privacy-updates.

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requestors are able to correct any information in their benefit request forms up to the point that
they sign and submit the filing. After the benefit request has been submitted, the only changes the
benefit requestor may make are at the account level, such as updating an email address or other
contact information. When inputting data from a paper filing, the Lockbox facilities employ quality
control measures, including levels of review to prevent keying errors and verifying scan quality.
In general, in the event of an error, the requestor is able to correct certain data using existing
correction processes, such as contacting USCIS NCSC.
Select data submitted by requestors are run through the A-Number validation process to
promote data integrity between USCIS ELIS and CIS. Information is validated from other systems
as needed. USCIS ELIS also enables the adjudicator to check biographical data (e.g., name, date
of birth, place of birth, gender) against data from CIS to assist the adjudicator in identifying
inaccurate data supplied by the requestor or correcting inaccurate data on file in legacy systems.
Finally, USCIS automatically submits data to other federal, DHS, and USCIS systems to verify
identity and conduct background and security checks.
USCIS only collects and uses external sources and publicly available information that is
reasonably related to matters under USCIS consideration. No decisions are based solely on the
collection of external information, including social media information. USCIS gives individuals
opportunities during and after the completion of the application process to correct information they
have provided and to respond to information received from external sources. If the information
could lead to a denial of the immigration benefit and if it is information of which the applicant is
unaware, it would be provided to the applicant in a Notice of Intent to Deny, in an interview, or in
similar processes, and the applicant would have an opportunity to review and respond.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk that requestors could submit more information than necessary
because USCIS ELIS houses multiple benefit requests that each require different information.
Mitigation: USCIS ELIS collects information pertaining to one benefit request at a time
so the requestor cannot be prompted to enter information unless it pertains to the specific benefit
request for which the requestor is filing. The information collected for benefit requests is the same
for paper and electronic filings.
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

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are negotiated with and approved by Office of Management and Budget during PRA collection
review. USCIS designed USCIS ELIS 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 USCIS ELIS to establish the identity of the benefit requestor
or beneficiary and to process the benefit request to determine benefit eligibility.
Privacy Risk: There a risk that information received from external sources could be
inaccurate, resulting in a denial of benefits.
Mitigation: This risk is mitigated. USCIS gives individuals opportunities during and after
the completion of the application process to correct information they have provided or received,
and to respond to information received from external sources. If the information could lead to a
denial of the immigration benefit and if it is information of which the benefit requestor is unaware,
it would be provided to the applicant in a NOID, in an interview, or in similar processes, and the
applicant would have an opportunity to review and respond.
Privacy Risk: There is a risk USCIS may rely on inaccurate information coming from
social media to make a decision.
Mitigation: This risk is partially mitigated. Information is collected directly from benefit
requesters, and individuals generally have some degree of control over what is posted on their
social media account. USCIS presumes some of this information is accurate. During the interview,
the officer will review any social media assessments provided by FDNS, including those with
possible inaccurate information, and address the underlying eligibility concern as annotated on the
social media assessment with the applicant and elicit testimony as indicated. FDNS has also
indicated that officers may provide the applicant with an opportunity to view the social media post
(the post only, not the entire social media assessment) and provide additional testimony explaining
any postings. Information collected from social media, by itself, will not be a basis to deny benefit
requests. USCIS has also developed procedures and training focused on understanding data quality
limitations associated with social media.

Section 3.0 Uses of the Information
3.1

Describe how and why the project uses the information.

USCIS ELIS is an electronic case management system that stores information to support
the processing of benefit request forms. USCIS uses the information to fulfill the following
adjudicative actions:


Verify the identity of the requester;



Identify missing information and make requests for additional information;

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

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.

Submissions to USCIS ELIS may originate in an electronic format or be converted to an
electronic format from paper and may include forms and supporting documentation associated
with each submission. This includes notices of agency action (e.g., appointment notices, requests
for evidence or originals, notices of intent to deny, or other final agency decisions) on a specific
application, petition, or request, whether filed directly online or received by USCIS in a paper
format and subsequently scanned for integration into the USCIS ELIS.

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?

USCIS ELIS shares read-only information with the USCIS Enterprise Service Bus (ESB),55
which may share information from USCIS ELIS with other components via PCQS.56 Through
PCQS, USCIS provides U.S. Immigration and Customs Enforcement (ICE) and CBP read-only
access to ELIS data. Both agencies are within DHS and share immigration-related missions.

55
56

See DHS/USCIS/PIA-008 Enterprise Service Bus available at www.dhs.gov/privacy.
See DHS/USCIS/PIA-010 Person Centric Query System (PCQS) available at www.dhs.gov/privacy.

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3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that retaining records in electronic, rather than paper, format
will allow increased access to the information.
Mitigation: This risk is partially mitigated. USCIS mitigates this risk three ways. First, all
users of USCIS ELIS must receive role-based system training, which explains the purpose of the
data and includes reminders about proper PII handling. Second, the system tracks all access and
edits to requestor PII and stores that activity in back-end audit logs available to the USCIS Office
of Security Investigations for monitoring and action. Finally, USCIS ELIS employs a provisioning
process that verifies that every user requesting access to the system has a valid need to view data
in the system.
Privacy Risk: By retaining data in an active, online platform, USCIS ELIS poses a risk of
unauthorized exposure because the system could be attacked by an external entity.
Mitigation: USCIS recognizes that retaining data online makes that data potentially more
available to compromise. As a result, USCIS is building into its retention schedules a timeframe
after which data may be retained offline by the agency but not online with public access. This will
allow the agency to preserve records that should be maintained for their historical value but adds
some security from unauthorized access of outdated accounts because the information is behind
the firewall. This risk is also mitigated by IT security measures such as encryption of data in transit
and at rest and requiring secure two-factor authentication for login. The USCIS OA process
supports a near real-time review and evaluation of system vulnerabilities and risks and provides a
framework to support risk management decisions. Both the USCIS Office of Information
Technology and USCIS ELIS systems teams report any incidents to the DHS Emergency
Operations Center. USCIS also follows National Institute of Standards and Technology (NIST)
guidance SP 800-63-3 (Digital Identity Guidelines) and SP 800-63A (Enrollment and Identity
Proofing) to authenticate an individual’s identity to ensure data is accessed only by authorized
individuals.57
Privacy Risk: By creating an electronic immigration file in addition to the paper file,
USCIS ELIS poses a risk of further decentralizing the official file of a requestor and making the
record incomplete and inaccurate.
Mitigation: This is partially mitigated. USCIS recognizes that retaining data online and on
paper creates a risk for USCIS officials when receiving immigration requests. In the RAILS there
is a “flag” if a USCIS ELIS case with a paper file exists. This provides awareness that the A-file
content may exist in both paper and electronic formats. RAILS is an enterprise wide application
57

National Institute of Standards and Technology, U.S. Department of Commerce, NIST Special Publication 80063A Digital Identity Guidelines, Enrollment and Identity Proofing Requirements. June 2017.
https://pages.nist.gov/800-63-3/sp800-63a.html.

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that supports the USCIS mission to maintain control of alien/immigrant and receipt files. The
purpose of RAILS is to increase the ability of USCIS to track the movement of Alien/immigrant
and Receipt physical files.

Section 4.0 Notice
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, regardless of whether it is paper or electronic, contains a Privacy
Notice 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-018 Immigration Biometric and Background Check
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, benefit requestors have consented to
USCIS’s 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
request forms require the benefit requestor 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 benefit request and thus precludes the benefit requestor from receiving the benefit.

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that the public may not be aware that ICE and CBP have
access to USCIS ELIS data.
Mitigation: This risk is mitigated. USCIS provides general notice to individuals through
the publication of this PIA that ICE and CBP may access USCIS ELIS data. USCIS also provides
notice through its Privacy Notices that USCIS may share this information, as appropriate, for law
enforcement purposes or in the interest of national security.

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Privacy Risk: There is a risk that the public may not be aware that their information is
stored in USCIS ELIS because the user only interacts with the MyUSCIS Account Experience.
Mitigation: This risk is partially mitigated. USCIS issued this PIA and the
DHS/USCIS/PIA-071 MyUSCIS Account Experience58 to serve as notice that MyUSCIS Account
Experience replaces all aspects of the public-facing USCIS ELIS, and that USCIS ELIS continues
to serve as an internal electronic case management system for certain benefit request forms.

Section 5.0 Data Retention by the project
5.1

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

USCIS ELIS serves as the electronic record of an individual’s immigration history. The
system is also used to facilitate and track the adjudication of certain benefit requests. USCIS has
many retention schedules to cover different types of data in USCIS ELIS, including the A-File,
draft and filed forms, and systems.
Electronic Records
An individual's immigration history may be contained in the following materials and
formats: (1) A paper A-File; (2) an electronic record in EDMS or USCIS ELIS; or (3) a
combination of paper and electronic records and supporting documentation. USCIS ELIS
maintains certain benefit request forms filed with USCIS. All documentation submitted or created
in support of a USCIS benefit request is maintained in accordance with USCIS policy and NARA
retention schedules after being scanned into USCIS ELIS. Benefit request forms that were rejected
because the form was incomplete and/or not accompanied by the required signature or fee are
maintained for 6 years or less.59 These records have temporary value because they have little or no
research value. All other benefit request forms and other electronic records in USCIS ELIS are
designated as A-File records. A-File records are permanent, whether hard copy or electronic. These
records have permanent value because they document enduring legal rights and have high potential
research value. DHS transfers A-Files to the custody of NARA for retention for 100 years after
the individual’s date of birth.
USCIS ELIS Case Management
ELIS also serves as the electronic case processing, adjudication, and management functions
of certain filed benefit request forms with USCIS. The case management data in USCIS ELIS is
covered by the retention schedule for each form type. USCIS will update Appendix A to this PIA
for each form retention schedule.

58
59

See DHS/USCIS/PIA-071 MyUSCIS Account Experience, available at www.dhs.gov/privacy.
Please see Appendix A to view the USCIS Approved NARA Schedule for Form Types.

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5.2

Privacy Impact Analysis: Related to Retention

There is no risk associated with retention for USCIS ELIS. USCIS has a NARA-approved
retention schedule for the electronic record and case management components of USCIS ELIS.

Section 6.0 Information Sharing
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 USCIS ELIS with external 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.60 DOS has
read-only access to USCIS ELIS data through PCQS. Access to USCIS ELIS provides DOS
consular officers with 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.
USCIS ELIS queries the DOS Consolidated Consular Database (CCD) to retrieve
Immigrant Visa data, which includes biographic data, case data, photo, and fingerprint
identification number (FIN).61 Immigrant Visa issuance data from the DOS is sent in a daily batch
and ingested into USCIS ELIS. The data includes biographic data, visa case data, visa
identification number, visa issuance date, class of admission, date of entry, and port of entry.
Social Security Administration (SSA)
USCIS, DOS, and the SSA currently have a Memorandum of Understanding (MOU) in
place that covers the process by which SSA works with USCIS to issue SSNs and Social Security
60

Memorandum of Agreement between the Department of State and the Department of Homeland Security
regarding the sharing of visa and passport records and immigration and naturalization and citizenship records,
signed November 18, 2008.
61
See DOS CCD PIA (July 17, 2015), available at https://www.state.gov/documents/organization/242316.pdf.

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cards for immigrants through a process called Enumeration at Entry (EAE).62 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 ELIS 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. USCIS ELIS sends requests for SSN issuance for approved
Employment Authorization Documents cases when the requestor checks the appropriate boxes
when filing the I-765.63
Department of Justice (DOJ) Executive Office of Immigration Reform (EOIR)
USCIS ELIS queries Case Access System for EOIR64 (CASE) for information related to
the requestor to see if there has been any activity related to USCIS ELIS cases where a decision
has been challenged by the applicant and/or the attorney/representative.65 Where there is a case,
USCIS looks at data such as case type, data case was filed with EOIR, case filing, case decision,
case disposition, and document type.
U.S. Postal Service (USPS)
USCIS ELIS sends the address provided by the benefit seeker and receives USPS
standardized addresses from the USPS Address Standardization Web Tool called Address
Matching for Mail Processing. The USPS Address Standardization Web Tool corrects errors in
street addresses, including abbreviations and missing information, and supplies ZIP Codes and ZIP
Codes + 4. It supports up to five lookups per transaction.66

6.2

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

Department of State (DOS)
Sharing USCIS ELIS data via PCQS to DOS is compatible with the purpose of the system
because the DOS mission, like that of USCIS, includes ensuring lawful visits and immigration to
62

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.
63
Form I-765 includes checkboxes that allow USCIS to share information with SSA for employment benefits.
64
https://www.justice.gov/eoir/major-information-systems.
65
See DOJ EOIR-001 Records and Management Information System, 82 FR 24147, May 25, 2017.
66
See USPS Address Matching for Mail Processing at
https://about.usps.com/handbooks/as353/as353apdx_042.htm#ep1181417.

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the United States as dictated by the INA. This sharing is covered by the Routine Use “I” of the
DHS/USCIS-007 SORN,67 which states that data may be shared with “Department of State for the
purpose of assisting in the processing of benefit requests under the Immigration and Nationality
Act, and all other immigration and nationality laws including treaties and reciprocal agreements.”
SSA
Sharing USCIS data with SSA is compatible with the purpose of the system because
Section 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 “S” of the
DHS/USCIS-007 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 in accordance with any related agreements in effect
between the SSA, the DHS, and the Department of Labor entered into pursuant to 20 CFR
422.103(b)(3), 422.103(c), and 422.106(a), or other relevant laws and regulations.
Department of Justice (DOJ)
Sharing USCIS ELIS data with DOJ EOIR is compatible with the purpose of the system
because the EOIR mission is to administer the immigration court system. The sharing of
information is covered by the Routine Use “A” of the DHS/USCIS-007 SORN, which states that
data may be shared with “DOJ, including Offices of the United States Attorneys, or other federal
agency conducting litigation or in proceedings before any court, adjudicative, or administrative
body, when it is relevant or necessary to the litigation and one of the following is a part of the
litigation or has an interest in such litigation.”
USPS
USCIS shares a limited amount of information with USPS for the purpose of enabling
USPS and USCIS mission requirements. USCIS is required to collect fees, adjudicate benefit
request forms, and provide timely evidence of the approved benefit. As part of normal operating
procedures, USCIS contracts with USPS to serve as a courier service to transport and deliver
documents to the recipient.

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., DOS and SSA) fully outline
67

81 FR 72069 (Oct. 19, 2016).

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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 USCIS ELIS records sent to non-DHS partners.
Furthermore, USCIS updates individual USCIS ELIS case records to reflect that a specific check
(i.e., background or security 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 to ensure information shared is not used
beyond the original purpose of collection (immigration benefits). All prospective information
handlers must be authorized and complete privacy and security training before gaining access to
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 with an external agency.

Section 7.0 Redress
7.1

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

USCIS provide individuals with multiple avenues to access their information. Individuals
who hold online accounts may access their case information maintained in USCIS ELIS through
the MyUSCIS Account Experience. MyUSCIS Account Experience allows account holders to
directly and securely engage with USCIS to obtain case-related information. Account holders who
create online accounts must authenticate their access using their credentials and authentication
code. Once authenticated, individuals may access their accounts including the information they
used to create their profiles, such as name and address information. The information individuals

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may access includes a copy of the application they submitted, any notices or notifications
generated by USCIS, and information about the status of their application.
An individual seeking access to more of his or her information held by USCIS may gain
access to his or her records by filing a Freedom of Information Act (FOIA) or Privacy Act request.
Individuals not covered by the Privacy Act or Judicial Redress Act (JRA) still may obtain access
to records consistent with FOIA unless disclosure is prohibited by law or if the agency reasonably
foresees that disclosure would harm an interest protected by an exemption. Any individual seeking
access to his or her information should direct his or her request to the following address:
National Records Center
Freedom of Information Act/Privacy Act Program
P. O. Box 648010
Lee’s Summit, MO 64064-8010
Certain information requested may be exempt from disclosure under the Privacy Act because
records related to fraud, with respect to an individual, may sometimes contain law enforcement
sensitive information. The release of law enforcement sensitive information could possibly
compromise ongoing criminal investigations. Further information for Privacy Act and FOIA
requests for USCIS records can also be found at http://www.uscis.gov.

7.2

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

USCIS allows individuals with an online account to correct any information in their benefit
request form up until they electronically sign and submit the benefit request form through
MyUSCIS Account Experience. After the benefit request has been submitted, the only changes the
benefit requestor or legal representative may make are at the account level, such as updating an
email address or other contact information. If the benefit requestor or legal representative need to
correct inaccurate information on the benefit request form while the benefit is being adjudicated,
he or she may submit the request in writing and upload the request into MyUSCIS Account
Experience as unsolicited evidence or by mail. It is the adjudicator’s decision to incorporate the
corrected information, depending on the timing and validity of the information. For corrections
after the application has been adjudicated, the requestor would use the existing FOIA and Privacy
Act processes employed by USCIS, which depend on the type and context of the correction
requested.
Additionally, U.S. citizens and lawful permanent residents, as well as other persons with
records covered by the JRA, are afforded the ability to correct information by filing a Privacy Act
Amendment request under the Privacy Act. Covered individuals should submit requests to contest
or amend information contained in USCIS ELIS as discussed in Section 7.1. Individuals may direct
all requests to contest or amend information to the USCIS FOIA/PA Office. Requests must state

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clearly and concisely the information being contested, the reason for contesting it, the proposed
amendment, and clearly mark the envelope “Privacy Act Amendment.” This would only apply to
amendment of USCIS-held information. Persons not covered by the Privacy Act or JRA are not
able to amend their records through FOIA. Should a non-U.S. person find inaccurate information
in his or her record received through FOIA, he or she may visit a local USCIS Field Office to
identify and amend inaccurate records with evidence.

7.3

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

Individuals are notified about procedures for correcting their information through
MyUSCIS online account, Privacy Notices, the USCIS website, the NCSC, this PIA, and relevant
SORNs.

7.4

Privacy Impact Analysis: Related to Redress

There is no privacy risk with respect to redress. Throughout the benefit request process,
USCIS provides requestors multiple avenues to correct information. There is a process to update
records during the adjudication process and to respond to information received from other sources.
The information requested may be exempt from disclosure under the Privacy Act because
information contained within USCIS ELIS may contain law enforcement sensitive information,
the release of which could possibly compromise ongoing criminal investigations.

Section 8.0 Auditing and Accountability
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 federal, DHS, and
USCIS policies. This includes the USCIS privacy policies, SOPs, information sharing agreements,
orientation and training, rules of behavior, and auditing and accountability. USCIS ELIS is built
off of the Amazon Web Services (AWS) US East/West cloud platform. AWS is a multi-tenant
public cloud designed to meet a wide range of security and privacy requirements (e.g.,
administrative, operational, and technical controls) that is used by USCIS to protect data in
accordance with federal security guidelines.68 AWS is FedRAMP-approved and is authorized to
host PII.69 FedRAMP is a U.S. government-wide program that delivers a standard approach to the
security assessment, authorization and continuous monitoring for cloud services.

68

Public clouds are owned and operated by third-party service providers whereas private clouds are those that are
built exclusively for an individual enterprise.
69
https://marketplace.fedramp.gov/#/product/aws-us-eastwest?status=Compliant&sort=productName.

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USCIS employs technical and security controls to preserve the confidentiality, integrity,
and availability of the data, which are validated during the security authorization process and on
an ongoing basis. These controls mitigate privacy risks associated with authorized and
unauthorized uses, namely misuse and inappropriate dissemination of data. USCIS ELIS has
sophisticated role-based user access for operational users, as well as read-only users. These include
roles that separate duties for operators to ensure appropriate oversight of the adjudication, as well
as two levels of read-only roles to protect more sensitive data about a requestor from being
accessible to internal users who only have a need for some of the data. Additionally, USCIS ELIS
captures all user activity, including information changed and viewed, in audit logs, which are
logged, tracked, and reviewed on a weekly basis as required by the USCIS Ongoing Authorization
program.

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.
The Privacy Awareness training addresses appropriate privacy concerns, including Privacy Act
obligations (e.g., SORNs, Privacy Act Statements). The Computer Security Awareness training
examines appropriate technical, physical, personnel, and administrative controls to safeguard
information. USCIS provides USCIS ELIS users system-specific training on proper handling of
PII, as well as appropriate use of data according to each role.

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 appropriate
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. Access
permissions are periodically reviewed to ensure users are only given access to the system based
on a need-to-know.

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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.
USCIS ELIS data is subject to the USCIS formal review process for any data sharing agreements.
That process includes, at a minimum, review by the Privacy Office, Counsel, and program officials
entrusted with security of the data.

8.5

Privacy Impact Analysis: Related to the Accountability and
Integrity of the Information.

Privacy Risk: The data maintained by Amazon Web Services (AWS) for the purposes of
cloud hosting may be vulnerable to breach because security controls may not meet system security
levels required by DHS.
Mitigation: This risk is mitigated. USCIS is responsible for all PII associated with the
ELIS system, whether on a USCIS infrastructure or on a vendor’s infrastructure, and it therefore
imposes strict requirements on vendors for safeguarding PII data. This includes adherence to the
DHS 4300A Sensitive Systems Handbook, which provides implementation criteria for the rigorous
requirements mandated by DHS’s Information Security Program.70

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

Approval Signature
[Signed copy complete and on file with the DHS Privacy Office]
________________________________
Philip S. Kaplan
Chief Privacy Officer
Department of Homeland Security
70

See https://www.dhs.gov/publication/dhs-4300a-sensitive-systems-handbook.

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Appendix A
USCIS Approved NARA Schedule for Form Types
Form Number

Form Name

I-90

Application to Replace Permanent Resident
Card
Application For Travel Document
Application for Employment Authorization
Application for Temporary Protected Status
Consideration of Deferred Action for
Childhood Arrivals
Application for Naturalization

I-131
I-765
I-821
Form I-821-D
N-400

NARA Approved
Schedule
DAA-0566-2015-0004
DAA-0566-2016-0004
DAA-0566-2016-0005
DAA-0566-2016-0007
DAA-0566-2016-0006
DAA-0566-2016-0002

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Appendix B
USCIS Benefit and Service Types Processed in USCIS ELIS
Paper Online
Filings Filings

Form Number

Form Name

DOS Immigrant
Visa Packet
(includes data
from DS-260 and
I-864)

DOS Immigrant Visa Packet

G-28

Notice of Entry of Appearance as Attorney or
Accredited Representative [OMB No. 16150105]

X

X

I-90

Replacement of Permanent Resident Card
[OMB No. 1615-0082]

X

X

I-130

Petition for Alien Relative [OMB No. 16150012]

X

X

I-131

Application for Travel Document [OMB No.
1615-0013]

X

I-131A

Application for Travel Document (Carrier
Documentation) [OMB No. 1615-0135]

X

I-212

Application for Permission to Reapply for
Admission into the United States After
Deportation or Removal [OMB No. 16150018]

X

I-765

Application for Employment Authorization
[OMB No. 1615-0040]

X

I-765WS

Application for Employment Authorization
Worksheet [OMB No. 1615-0040]

X

I-821

Application for Temporary Protected Status
[OMB No. 1615-0043]

X

I-821D

Consideration of Deferred Action for
Childhood Arrivals [OMB No. 1615-0124]

X

X

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I-912

Request for Fee Waiver [OMB No. 16150116]

X

N-400

Application for Naturalization [OMB No.
1615-0052]

X

X

N-336

Request for a Hearing on a Decision in
Naturalization Proceedings Under Section 336
[OMB No. 1615-0050]

X

X

Application for Replacement
Naturalization/Citizenship Document [OMB
No. 1615-0091]

X

X

N-600

Application for Certificate of Citizenship
[OMB No. 1615-0057]

X

X

N-600K

Application for Citizenship and Issuance of
Certificate Under Section 322 [OMB No.
1615-0087]

X

X

N-565