DHS/CBP/PIA-073 Advanced Travel Authorization (ATA)

Privacy Impact Assessment
for the

Advance Travel Authorization
DHS Reference No. DHS/CBP/PIA-073
October 17, 2022

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Abstract
The U.S. Department of Homeland Security (DHS) is developing a new, voluntary
Advance Travel Authorization (ATA) process to collect information from eligible noncitizens
requesting advance authorization to travel to the United States to seek a discretionary grant of
parole. U.S. Customs and Border Protection (CBP) is publishing this new Privacy Impact
Assessment (PIA) to provide notice and assess the privacy risks associated with ATA. ATA
launched October 12, 2022, to implement a parole process for certain undocumented noncitizens
from select countries and their qualifying immediate family members, under which those
individuals may request advance authorization to travel to the United States to seek a discretionary
grant of parole. This Privacy Impact Assessment discusses the general workflow of ATA and the
information collected, stored, and used at each step. CBP’s ATA collection is conducted through
the CBP One™ mobile application, and CBP is publishing a CBP One™ Privacy Impact
Assessment appendix update concurrently with this ATA Privacy Impact Assessment.

Overview
On October 12, 2022, Secretary of Homeland Security Mayorkas announced the creation
of a new parole process for certain undocumented noncitizens from select countries. Under this
process, certain undocumented noncitizens from select countries (as identified in the Appendix to
this Privacy Impact Assessment) and their qualifying immediate family members, who are outside
of the United States and who lack visas or other appropriate entry documents, may utilize ATA to
request an advance authorization to travel to the United States to seek a discretionary grant of
parole. Parole allows an individual who may be inadmissible to the United States to be in the
United States for a temporary period for urgent humanitarian reasons or significant public benefit.
Generally, a citizen of a foreign country who wishes to enter the United States must first
obtain a valid travel authorization. Travel authorizations are typically issued as a visa by the U.S.
Department of State, or as an Electronic System for Travel Authorization (ESTA) for citizens of a
country that participates in the Visa Waiver Program (VWP).1 A travel authorization allows a
foreign citizen to travel to a U.S. port of entry and apply for admission to the United States. A
travel authorization does not guarantee entry into the United States. CBP officials at the port of
entry have authority to determine every individual’s admissibility to the United States. Regardless
of whether a traveler is issued a visa, an Electronic System for Travel Authorization, or ATA, a
CBP official will still determine admissibility during inspection at the port of entry.
The Immigration and Nationality Act (INA) allows DHS to exercise discretionary authority
to parole a non-U.S. citizen into the United States, on a case-by-case basis, temporarily for urgent
1

The Visa Waiver Program allows foreign nationals from certain countries to travel to the United States for business
or pleasure, for stays of 90 days or less without obtaining a visa.

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humanitarian reasons or significant public benefit.2 DHS has delegated parole authority to CBP,
as well as U.S. Immigration and Customs Enforcement (ICE) and U.S. Citizenship and
Immigration Services (USCIS).3 Parole allows an individual who may not have a valid entry
document (such as a visa or an Electronic System for Travel Authorization) into the United States
for a temporary period.4
Absent national security or public safety concerns, individuals arriving with an approved
advance authorization to travel to the United States to seek a discretionary grant of parole may be
considered for parole; however, inspecting CBP officers retain the discretion to process arriving
individuals on a case-by-case basis considering the totality of the circumstances. Using its
delegated authority to grant parole, CBP will determine, in an exercise of discretion, whether
parole is appropriate at the time that the individual presents themselves for inspection at a U.S.
port of entry. The inspecting CBP officer considers the totality of the circumstances when making
disposition determinations.
Advance Travel Authorization Process
The new, voluntary ATA process is available to certain undocumented noncitizens from
select countries, and their qualifying immediate family members, who are outside of the United
States and who lack visas or other entry documents. Appendix A of this Privacy Impact
Assessment contains a current list of the ATA eligible countries. ATA eligible noncitizens
(referred to throughout the rest of this Privacy Impact Assessment as “travelers”) will follow the
ATA process, and if approved, will receive an advance authorization that will permit them to travel
to the United States to seek parole. If the ATA is denied, the individual will not be authorized to
travel to the United States under this process but may pursue other existing avenues to obtain valid
United States entry documents such as a visa. The ATA process consists of multiple steps with
data capture, verification, and vetting conducted by both USCIS and CBP, in collaboration with
the National Vetting Center (NVC). The public facing systems used in the ATA process are
USCIS’s myUSCIS and CBP’s CBP One™ mobile application. Additionally, CBP conducts
traveler vetting through the Automated Targeting System (ATS) and other systems, while CBP’s
Advance Travel Information System (ATIS) is responsible for storing and moving the data.5

2

See 8 U.S.C. § 1182(d)(5); 8 C.F.R. § 212.5.
See DHS Delegation Orders: Delegation of Authority to the Commissioner of U.S. Customs and Border Protection;
Delegation No. 7010.3, Sec. 2(B)(15).
4
An individual who is paroled into the United States has not been admitted into the United States for purposes of
immigration law.
5
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE AUTOMATED TARGETING SYSTEM, DHS/CBP/PIA-006(e)
(2017), available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
3

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1. myUSCIS
To initiate the process of requesting an advance travel authorization, a U.S.-based supporter
electronically files USCIS Form I-134,6 Declaration of Financial Support, on behalf of the traveler
and/or traveler family members. Using this form, USCIS collects personally identifiable
information on (1) the U.S.-based supporter, (2) the traveler;7 (3) an interpreter (if any); and (4)
the preparer of the form (if different than the supporter). USCIS uses the information on this form
to conduct vetting on the supporter and determines whether the supporter has established a basis
of support for the traveler(s).
Following approval of the I-134, USCIS will assign each traveler an A-Number—if they
do not already have an assigned A-Number—and will notify the traveler electronically with an
invitation to create a myUSCIS account. myUSCIS is a USCIS-owned digital environment where
individuals create a secure account to use various digital services and access pending case
information.8 Travelers use their myUSCIS account to verify their biographic information as
collected on the Form I-134 is accurate and attest to all requirements. Once the traveler has
confirmed their biographic information, myUSCIS informs them to use the CBP One™ mobile
application to continue the process.
USCIS sends the I-134 and A-Number with supporting biographic data to CBP, which CBP
stores in the Arrival and Departure Information System (ADIS).9 CBP One™ (described below)
validates the traveler’s data including their A-Number and passport number against USCISprovided data stored in the Arrival and Departure Information System and sends this information
to CBP’s Advanced Traveler Information System. CBP creates a pending ATA and sends the
traveler’s ATA process data to CBP’s Automated Targeting System/Unified Passenger system
(UPAX) and the National Vetting Center for ATA vetting. Based on vetting results, CBP’s Predeparture Service10 provides an ATA status (approved or not approved) to the airlines (if an
individual travels by air). CBP also sends ATA status to USCIS to update the traveler’s myUSCIS
account submission status (Travel Authorized or Travel Not Authorized). Travelers authorized to
travel may book commercial airline travel to a U.S. port of entry.

6

See Form I-134 Declaration of Financial Support, available at https://www.uscis.gov/i-134.
A separate Form I-134 is required for each traveler and eligible family members.
8
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITZENSHIP AND IMMIGRATION SERVICES,
PRIVACY IMPACT ASSESSMENT FOR THE myUSCIS Account Experience, DHS/USCIS/PIA-071, available at
https://www.dhs.gov/uscis-pias-and-sorns.
9
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE ARRIVAL AND DEPARTURE INFORMATION SYSTEM,
DHS/CBP/PIA-024, available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
10
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE TECS SYSTEM: PLATFORM, DHS/CBP/PIA-021, available at
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
7

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2. CBP One™
Once the affidavit of support and associated requirements are complete, USCIS will inform
the traveler to complete their request for advance authorization to travel by downloading the CBP
One™ mobile application. Once the CBP One™ mobile application is downloaded, the user must
select “Traveler,” then “Air,” then “Advance Travel Authorization,” then “Request Advance
Travel Authorization.” The first time a traveler accesses CBP One™, they will be prompted to
provide their first and last name in their profile. After the traveler’s name is collected, the traveler
will then be directed to manually enter their myUSCIS-provided A-Number.
CBP One™ will then direct the user to “Scan Passport.” The CBP One™ mobile
application will then display a pop-up notifying the user that the mobile application is accessing
the mobile device’s camera. Once the camera is enabled, the mobile application prompts the user
to position the mobile device’s camera over the passport’s biographic page. Once the biographic
page of the passport is scanned, CBP One™ will determine whether there is a readable eChip11
imbedded in the passport. If there is a readable eChip, CBP One™ will decode the chip and retrieve
the photograph, date of birth, and travel document number associated with the passport. If there is
no useable eChip, CBP One™ will collect the photograph on the biographic page and scan the
Machine-Readable Zone (MRZ) of the passport to collect the date of birth and passport number,
nationality. This biographic information is then automatically populated into the submission of the
mobile application to eliminate the need for manual input by the traveler.
In addition to the collection of the biographic information, users who have eChips will be
prompted to place their mobile device near the passport’s eChip. By placing the mobile device
near the eChip, the mobile device enables the Near Field Communication12 capability to wirelessly
retrieve the biometric data stored within the eChip. The biometric information on the eChip
includes the passport photograph and country signing certificate to certify the authenticity of the
passport.
Once the biographic and eChip data is collected, CBP One™ prompts the user to take a
live photograph or “selfie.” CBP One™ instructs the user to line their face up with a circle on the
screen of their mobile device. CBP One’sTM imbedded software then performs a “liveness” test to

11

An e-Passport contains an electronic chip. The chip holds the same information that is printed on the passport's
data page: the holder’s name, date of birth, and other biographic information. An e-Passport also contains a
biometric identifier. The United States requires that the chip contain a digital photograph of the holder. All ePassports issued by Visa Waiver Program countries and the United States have security features to prevent the
unauthorized reading or “skimming” of data stored on the e-Passport chip. See https://www.dhs.gov/e-passports.
12
Near Field Communication describes a technology which can be used for contactless exchange of data over short
distances. Two Near Field Communication-capable devices are connected via a point-to-point contact over a short
distance. This connection can be used to exchange data between the devices.

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determine that it is real person (and not a picture of a person).13 CBP One™ allows the user to
capture their image and select “Continue” once they satisfied it is an accurate photo. CBP One™
will reject any images that are not correctly captured. If the user is not satisfied with the image
captured, the user can retake the image. There is currently no limitation to the number of attempts
to retake the selfie to ensure a proper image. If they continue to have technical difficulties, the
CBP One™ application provides a help desk email address to provide assistance.
Once the capture of the live photo is verified, the CBP OneTM application will display a
summary page with all information collected and allow the user to return to previous pages to
modify their submission to correct anything that may have been collected incorrectly. Once the
user verifies and submits their information, the data and photographs are passed to downstream
systems described below. The CBP OneTM application will advise the user to refer to their
myUSCIS account for further information on their request.
CBP One™ collects and sends the A-Number, date of birth, and passport number to the
CBP Arrival and Departure Information System in order to verify the traveler accessing the
specific functionality within CBP One™ has a USCIS-approved U.S.-based supporter, has verified
their biographic information, and has provided the DHS required attestations related to program
eligibility criteria.14 The Arrival and Departure Information System directly interfaces with
USCIS’s Electronic Immigration System (ELIS), which is used to process immigration benefits.15
If the Arrival and Departure Information System confirms the information to be valid, a
confirmation will be sent back to CBP OneTM, and then CBP OneTM will send the biographic
information, A-number, and passport number to the Automated Traveler Information System for
vetting.16 CBP uses the passport number to conduct document verification in TECS, the primary
system used by CBP officers at the border to assist with screening and admissibility, to determine
if the document is valid.17 If CBP cannot confirm that the traveler has been approved by USCIS
13

While the user is taking the selfie, the technology embedded within the mobile application relies on the device’s
camera to view a live image through 3D face changes and observing perspective distortion to prove the image is 3D.
If “liveness” cannot be confirmed, the user is unable to utilize the CBP OneTM application.
14
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE ARRIVAL AND DEPARTURE INFORMATION SYSTEM
(ADIS), DHS/CBP/PIA-024, available at https://www.dhs.gov/privacy-impact-assessments.
15
See DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION SERVICES
(USCIS), PRIVACY IMPACT ASSESSMENT FOR THE ELECTRONIC IMMIGRATION SYSTEM (USCIS
ELIS), DHS/USCIS/PIA-056, available at https://www.dhs.gov/privacy, and DHS/USCIS-007 Benefits Information
System, 81 FR 72069 (October 19, 2016).
16
The Advanced Traveler Information System is a web-based application and screening system used to vet
undocumented noncitizens applying for advance authorization to travel to the United States and seeking parole.
17
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE TECS SYSTEM: CBP PRIMARY AND SECONDARY
PROCESSING, DHS/CBP/PIA-009 (2010 and subsequent updates), and U.S. DEPARTMENT OF HOMELAND
SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT ASSESSMENT FOR THE

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for ATA or identify a valid passport the traveler will not be able to complete their request for
advance authorization to travel.
Once all the required information and photograph are submitted, the information is saved
in the Advanced Traveler Information System and copied to Automated Targeting System- Unified
Passenger system for biographic and biometric (photograph) vetting. CBP does not search or enroll
photographs submitted via the CBP One™ mobile application to the Automated Biometric
Identification System/Homeland Advanced Recognition Technology System (IDENT/HART).18
CBP One™ informs the traveler that CBP has received the information and it is being reviewed
and reminds the traveler to check their myUSCIS account for any updates. In addition to this
Privacy Impact Assessment, CBP has completed an appendix update to the CBP One™ Privacy
Impact Assessment which provides full detail on the data collection process in CBP One™ for
ATA travelers.
Uses of Facial Comparison During ATA Process
CBP uses facial comparison technology at various stages in the ATA process. After CBP
One™ captures the photograph, it first sends that image to the Advanced Traveler Information
System where CBP uses it for several different purposes.
CBP uses the selfie image for five distinct purposes: (1) to conduct one-to-one (1:1) facial
comparison against the passport photograph previously uploaded to the ATA CBP One™ function
from the eChip; (2) to conduct one-to-many (1:n) vetting against derogatory photographic holdings
for law enforcement and national security concerns as part of the ATA vetting process; (3) to
generate a new gallery of ATA participants for facial comparison when ATA participants arrive at
a port of entry; (4) to conduct 1:n identity verification once the participants arrive at the port of
entry; and (5) to conduct 1:n vetting against known derogatory photographs for assistance in CBP’s
admissibility determination.

TECS SYSTEM: PLATFORM, DHS/CBP/PIA-021 (2016), available at https://www.dhs.gov/privacy-impactassessments.
18
See U.S. DEPARTMENT OF HOMELAND SECURITY, OFFICE OF BIOMETRIC IDENTITY
MANAGEMENT, PRIVACY IMPACT ASSESSMENT FOR THE AUTOMATED BIOMETRIC
IDENTIFICATION SYSTEM (IDENT), DHS/OBIM/PIA-001 (2012), available at
https://www.dhs.gov/privacydocuments-office-biometric-identity-management-obim. DHS is in the process of
replacing the Automated Biometric Identification System with the Homeland Advanced Recognition Technology
System as the primary DHS system for storage and processing of biometric and associated biographic information.
For more information about the Homeland Advanced Recognition Technology System, please see U.S.
DEPARTMENT OF HOMELAND SECURITY, OFFICE OF BIOMETRIC IDENTITY MANAGEMENT,
PRIVACY IMPACT ASSESSMENT FOR THE HOMELAND ADVANCED RECOGNITION TECHNOLOGY
SYSTEM (HART) INCREMENT 1, DHS/OBIM/PIA-004 (2020), available at
https://www.dhs.gov/privacydocuments-office-biometric-identity-management-obim.

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Using the Traveler Verification Service (TVS)19 functionality within the Automated
Targeting System-Unified Passenger system, CBP compares the two photographs to conduct a 1:1
match with the selfie and the user’s passport photograph to biometrically verify the user’s identity.
If the two photographs are a match, Automated Targeting System-Unified Passenger system will
send a match response back to CBP One™. CBP One™ allows the user to capture their image and
confirm submission after viewing the captured image. CBP One™ will only allow submission of
an image of sufficient quality. If the image is not of sufficient quality or the user is otherwise not
satisfied with the image captured, the user can retake the image until a quality image is captured.
There is currently no limitation to the number of attempts to retake the selfie to ensure a proper
image. If the individual continues to have technical difficulties, the CBP One™ application
provides a help desk email address to provide assistance.
Once the 1:1 biometric verification is complete, the CBP OneTM application will display a
summary page with all information collected and allow the user to edit anything that may have
been collected incorrectly. Once the user verifies and submits their information, the vetting process
begins, and the mobile application will advise the user to refer to their myUSCIS account for
further information on their request.
When all the required information and photograph are submitted, the information is saved
in the Advanced Traveler Information System and copied to Automated Targeting System-Unified
Passenger system for biographic and biometric (photograph) vetting. CBP does not search or enroll
photographs submitted via the CBP One™ mobile application to the IDENT/HART20 system. CBP
One™ informs the traveler that CBP has received the information and it is being reviewed and
reminds the traveler to check their myUSCIS account for any updates. In addition to this Privacy
Impact Assessment, CBP has completed an appendix update to the CBP One™ Privacy Impact
Assessment which provides full detail on the data collection process in CBP One™ for ATA
travelers.
3. Advance Travel Information System
CBP stores information collected from travelers via CBP One™ in CBP’s Advance Travel
Information System. The Advanced Traveler Information System is a storage system used by CBP
to automatically coordinate vetting by sending information collected via CBP One™ and USCIS
to the vetting systems and receiving a consolidated response. Upon receipt, the Advanced Traveler
CBP’s TVS is an accredited information technology system consisting of a group of similar systems and
subsystems that support the core functioning and transmission of data between CBP applications and partner
interfaces. Since early 2017, CBP has used the TVS as its backend matching service for all biometric entry and exit
operations that use facial recognition, regardless of air, land, or sea. See U.S. DEPARTMENT OF HOMELAND
SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT ASSESSMENT FOR THE
TRAVELER VERIFICATION SERVICE, DHS/CBP/PIA-056 (2018), available at
https://www.dhs.gov/privacydocuments-us-customs-and-border-protection.
19

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Information System provides traveler ATA data to CBP’s Automated Targeting System21 where it
is vetted against selected DHS and other federal agency security and law enforcement databases
for national security, border security, public health, and safety concerns. In addition, the
Automated Targeting System will share that biographic data with the National Vetting Center for
classified vetting support.22 CBP conducts this vetting to determine whether the beneficiary poses
a security risk to the United States and whether they may be eligible to obtain advance
authorization to travel to the United States to seek a discretionary grant of parole. The results of
this vetting help to inform CBP’s assessment of whether the beneficiary’s travel poses a law
enforcement or security risk and whether the request should be approved. CBP consolidates both
the unclassified and classified vetting results in the Advanced Traveler Information System and
sends an approval or denial message to USCIS.
If the ATA submission is denied, the beneficiary is not eligible to receive an advance
authorization to travel to the United States to seek a discretionary grant of parole under this
process. CBP retains all ATA denials in the same manner as Electronic System for Travel
Authorization denials, where they are treated as a law enforcement record and stored for 75 years.
If the submission is approved, the approval establishes that the beneficiary has obtained advance
authorization to travel to the United States to seek parole but does not guarantee boarding or a
specific processing disposition. Upon arrival at a U.S. port of entry, the traveler will be subject to
inspection by a CBP officer, who will make a case-by-case processing disposition determination.
4. Entry and Processing
Upon arrival at a U.S. port of entry, travelers will undergo inspection and examination in
the same manner as any other traveler. If traveling by commercial air to the United States under
the ATA process, individuals must show their ATA submission status along with a valid passport
and other appropriate identification to airline personnel. Air carriers that participate in CBP’s
Document Validation program23 can validate an approved and valid travel authorization
submission using the same mechanisms that are currently in place to validate that a traveler has a
valid visa or other documentation to facilitate issuance of a boarding pass for air travel. Carriers
not participating in CBP’s Document Validation program may request verification of the traveler’s
Travel Authorization status by viewing the individual’s myUSCIS account and should contact the
Regional Carrier Liaison Group (RCLG) if additional confirmation of the travel authorization
status is warranted.

22

See U.S. DEPARTMENT OF HOMELAND SECURITY, PRIVACY IMPACT ASSESSMENT FOR THE
NATIONAL VETTING CENTER, DHS/ALL/PIA-072, available at https://www.dhs.gov/privacy-documentsdepartment-wide-programs.
23
See CBP Carrier Liaison Program for more information available at https://www.cbp.gov/travel/travel-industrypersonnel/carrier-liaison-prog.

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All individuals are subject to inspection by a CBP officer upon arrival at a U.S. port of
entry. Although the population utilizing this process will be arriving at the port of entry with an
approved ATA submission, they will not be in possession of valid United States entry documents.
Therefore, consistent with current policy, these individuals will be referred for secondary
inspection. The Unified Secondary system (USEC)25 will display an individual’s travel
authorization submission and travel authorization status as part of the system checks conducted
during inspection to allow the inspecting officer to determine the appropriate processing
disposition.
24

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?

Pursuant to 8 U.S.C. § 1182(d)(5), CBP has the authority and discretion to grant parole to
noncitizens, as appropriate, on a case-by-case basis, for urgent humanitarian reasons or significant
public benefit.26 Pursuant to 8 C.F.R. § 212.5(f), DHS may issue an “appropriate document
authorizing travel” to a noncitizen without a visa who is traveling to the United States to seek
parole.

1.2

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

The Automated Targeting System (ATS) System of Records Notice (SORN)27 covers the
24

See 8 C.F.R. Part 235 Inspection of Persons Applying for Admission. If an individual arrives at a port of entry
without sufficient documentation, as part of standard processing the CBP officer typically refers the individual for a
secondary inspection. For a full description of the privacy risks and mitigations associated with CBP primary and
secondary processing procedures, please see U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS
AND BORDER PROTECTION, PRIVACY IMPACT ASSESSMENT FOR THE TECS SYSTEM: CBP
PRIMARY AND SECONDARY PROCESSING, DHS/CBP/PIA-009 (2010 and subsequent updates); TECS
SYSTEM PLATFORM, DHS/CBP/PIA-021 (2016), available at https://www.dhs.gov/privacy-documents-uscustoms-and-border-protection.
25
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR UNIFIED SECONDARY, DHS/CBP/PIA-067 (2021 and subsequent
updates), available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
26
Parole allows a noncitizen to temporarily enter the United States where such parole provides a significant public
benefit or is for an urgent humanitarian reason. The Immigration and Nationality Act (INA) allows
authorized DHS officials to use their discretion to parole any noncitizen applying for admission into the United
States for urgent humanitarian reasons or significant public benefit (See 8 U.S.C. § 1282(d)(5); 8 C.F.R.
§ 212.5). An individual who is paroled into the United States has not been admitted into the United States
for purposes of immigration law.
27
See DHS/CBP-006 Automated Targeting System, 77 FR 30297 (May 22, 2012), available at
https://www.dhs.gov/system-records-notices-sorns.

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collection of information from persons, including operators, crew, and passengers, who seek to, or
do in fact, enter, exit, or transit through the United States by land, air, or sea, or through other
locations where CBP maintains an enforcement or operational presence. Information from
travelers requesting advance authorization to travel to the United States to seek parole is broadly
covered by the Automated Targeting System System of Records Notice. CBP compares the
advance information against law enforcement and intelligence databases, which allows CBP to
identify individuals and cargo requiring additional scrutiny, which aligns to the border security
mission of the Department.
The Alien File, Index, and National File Tracking System of Records Notice28 covers the
A-number and information regarding transactions involving an individual as they pass through the
U.S. immigration process. The Benefit Information System (BIS) System of Records Notice29
covers information contained in myUSCIS.

1.3

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

The user’s biographic data, passport number, and citizenship data submitted through the
CBP One™ application is stored in an Amazon Web Services cloud for 365 days for purposes of
reporting aggregate data for CBP leadership. CBP One™ will not store any photographs. CBP
One™ also collects the first and last name of the user as part of the profile creation and this
information is stored locally on the user’s device to create a user profile within CBP One™ so that
the user can quickly retrieve information for subsequent use.
Advanced Traveler Information System data resides within the e-Business Cloud security
boundary. The e-Business Cloud Authority to Operate (ATO) was last renewed in June 2022.
Advanced Traveler Information System information is also transferred and stored in the
Automated Targeting System, for 15 years. The Automated Targeting System underwent the
security authorization process in accordance with DHS and CBP policy, which complies with
federal statutes, policies, and guidelines. The Automated Targeting System received a renewed
Authority to Operate on January 15, 2020.

1.4

28

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

See DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 FR 43556
(September 18, 2017), available at https://www.dhs.gov/system-records-notices-sorns.
29
See DHS/USCIS-007 Benefit Information System (BIS) System of Records, 84 FR 54622 (October 10, 2019),
available at https://www.dhs.gov/system-records-notices-sorns.

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No. CBP is in the process of developing formal records retention schedule(s) for ATA and
other traveler encounter records. However, the various types of data collected by the ATA process
have various proposed records schedules:
1. CBP stores the Form I-134 basic biographic information submitted by supporters
within the Arrival and Departure Information System consistent with its retention
schedule of 75 years, and consistent with other information received from USCIS on
various immigration forms.
2. The Arrival and Departure Information System then passes the basic biographic
information to the Advanced Traveler Information System where it is combined with
the user-submitted data from CBP One™ and stored for 15 years, consistent with the
Electronic System for Travel Authorization retention schedule (another advance travel
authorization program).
3. CBP also stores a copy of this information within the Automated Targeting System as
a copy from the Advanced Traveler Information System for faster vetting. While most
Automated Targeting System records are retained for 15 years, records that are of law
enforcement interest, such as an ATA denial, are stored consistent with other law
enforcement encounters for 75 years.
4. CBP One™ is a passthrough for information and does not store any official biographic
or biometric record. The user’s biographic data, passport number, and citizenship data
submitted through the CBP One™ application is stored in a CBP-owned cloud storage
solution for 365 days for auditing purposes and reporting aggregate data.
5. For the selfie photograph used only for identity verification against the traveler’s
passport photograph, CBP will store this photograph in the Automated Targeting
System and the Advanced Traveler Information System for the duration of the validity
of the travel authorization (generally 90 days unless granted an extension), or traveler
passport expiration date (whichever is sooner).
6. For photographs collected as part of the entry process at the port of entry, these records
are stored for 75 years consistent with the DHS Office of Biometric Information
Management (OBIM) current Record Schedule DAA-0563-2013-0001. This schedule
covers DHS biometric and biographic records used for national security, law
enforcement, immigration, and other functions.

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.

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CBP is concurrently seeking a new emergency approval from the Office of Management
and Budget (OMB) under the Paperwork Reduction Act to permit this collection.

Section 2.0 Characterization of the Information
2.1

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

CBP receives the information listed below from USCIS, submitted by the supporter about
the traveler(s) via the Form I-134, and stores it in the Arrival and Departure Information System,
Advanced Traveler Information System, and Automated Targeting System-Unified Passenger
system:
•

Full name (first, middle, last)

•

Date of birth

•

Gender

•

Receipt number

•

Form type

•

Case status

•

Event date

•

A-Number

•

Country of citizenship

•

Country of birth

•

Country of residence

•

Passport number

•

Document country of issuance

•

Passport issue date

•

Passport expiration date

•

Physical address (street, city, state, country, zip code)

•

Telephone number (home, mobile, other)

•

Email address

•

Birthplace (city, state, country)

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•

USCIS ELIS account number

In addition to the data passed to CBP from USCIS, CBP collects information directly from the
traveler via CBP One™. When prompted by USCIS to create an account and continue to the
advance travel authorization process, the traveler logs into CBP One™ using a Login.gov account
and enters their A-Number. CBP One™ validates the traveler’s A-Number against the A-Number
stored in the Arrival and Departure Information System. The traveler scans their passport using
embedded Machine-Readable Zone scan technology in CBP One™ which auto-captures the
passport number, date of birth and citizenship, as well as a photograph either via eChip in
ePassports or directly from the passport’s biographic page. Finally, CBP One™ collects a live
photograph or selfie.
CBP creates the full Advanced Traveler Information System record using the traveler’s ANumber, passport number, date of birth, travel document photograph and selfie from CBP One™,
and from the Form I-134 biographic information submitted from USCIS via CBP’s Arrival and
Departure Information System.

2.2

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

For the ATA process, USCIS and CBP collect this information directly from the
individuals applying as U.S.-based supporters, and from the individual(s) seeking to obtain
advance authorization to travel to the United States.

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. CBP may vet submissions against commercial sources and/or publicly available data,
including social media information, through its established vetting procedures. This information
provides supplemental data about persons or businesses as part of the analysis process for
researching individuals requiring additional vetting.

2.4

Discuss how accuracy of the data is ensured.

CBP collects this information directly from the supporter seeking to obtain advance
authorization to travel for certain eligible noncitizens (via myUSCIS), and from the travelers
themselves. While there is always an inherent risk to manual data entry, CBP provides individuals
with the opportunity to review and verify the information prior to submission to CBP.
Additionally, once an individual presents him or herself for inspection upon arrival at a port of
entry, a CBP officer verifies and updates any information in inspection systems that is incorrect or
inaccurate.

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2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a privacy risk that individuals will be denied an ATA if the facial
recognition tools determine a “no match” between the new selfie and an individual’s travel
document.
Mitigation: This risk is mitigated. CBP One™ allows the user to capture their image and
confirm submission after viewing the captured image. If the user is not satisfied with the image
captured, the user can retake the image. There is currently no limitation to the number of attempts
to retake the selfie to ensure a proper image. If they continue to have technical difficulties, the
CBP One™ application provides a help desk email address to provide assistance. CBP One™ will
only allow submission of an image of sufficient quality.
There are two types of facial comparison used for ATA. The first is a 1:1 match for identity
verification against an individual’s travel document photograph and a new, live selfie as part of
the CBP One™ process. This 1:1 match has a very high match accuracy rate since the match is
one photograph to another one photograph.
The second is a 1:n match using the newly submitted ATA selfie photograph against other
CBP holdings of derogatory photographs. A match against a known derogatory photograph does
not automatically trigger an ATA denial; rather, the entire ATA submission will be manually
reviewed by a CBP officer to determine whether the match is accurate and whether the ATA should
be denied.
Privacy Risk: There is a risk of overcollection since CBP may collect information from
individuals who do not actually arrive at the port of entry.
Mitigation: This risk is partially mitigated. CBP is collecting this information from
individuals who are seeking to obtain advance authorization to travel to the United States to seek
parole. Individuals voluntarily provide this information to CBP. This information collection is
similar to other advance information collections, such as Advance Passenger Information System
(APIS)30 data and Electronic System for Travel Authorization 31 data. In this circumstance, CBP
also collects and retains information on individuals who may intend to travel but do not actually
travel to the United States. This advance information, combined with the results of the pre-vetting,
30

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE ADVANCE PASSENGER INFORMATION SYSTEM,
DHS/CBP/PIA-001 (2008 and subsequent updates), available at https://www.dhs.gov/privacy-documents-uscustoms-and-border-protection.
31
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE ELECTRONIC SYSTEM FOR TRAVEL AUTHORIZATION,
DHS/CBP/PIA-007 (2008 and subsequent updates), available at https://www.dhs.gov/privacy-documents-uscustoms-and-border-protection.

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is used by CBP to identify public safety threats (such as wants/warrants) and national security
threats (such as links to terrorist organizations).
Privacy Risk: There is a risk that information submitted to CBP will be inaccurate.
Mitigation: This risk is mitigated. Though supporters submit the initial biographic
information about travelers, all travelers are granted access to myUSCIS, where they can verify
their biographic information as collected on the Form I-134 is accurate and attest to all
requirements. Once the traveler has confirmed their biographic information, myUSCIS informs
them to use the CBP One™ mobile application to continue the process.
All information that CBP collects through CBP One™ is done automatically through either
a scan of the Machine-Readable Zone on the passport or decoding the eChip embedded in the
passport. Absent fraud, CBP can rely on this information being accurate. If the information
submitted through CBP One™ does not match the information in the approved Form I-134, the
user is advised to return to their myUSCIS account and verify the information is accurate and
matches the submission in CBP One™.
Privacy Risk: There is a risk that CBP is collecting more information than necessary to
issue a travel authorization.
Mitigation: This risk is mitigated. CBP is collecting the same biographic information that
is typically collected from individuals seeking to travel to the United States (e.g., Advance
Passenger Information System, Electronic System for Travel Authorization, Form I-94,
Arrival/Departure Record, or Form I-94W, Nonimmigrant Visa Waiver Arrival/Departure
Record),32and the same biographic and biometric information as part of a U.S. Department of State
visa application. Additionally, the information collected in advance of an individual’s arrival is
consistent with the information that CBP normally collects at the port of entry during the inspection
in accordance with existing CBP processes.

Section 3.0 Uses of the Information
3.1

Describe how and why the project uses the information.

CBP uses the information from the ATA submission to grant or deny advance authorization
for an individual to travel to the United States to seek parole. CBP also uses the information to
determine whether the individual seeking advance authorization to travel poses a law enforcement
or security risk to the United States.33 CBP vets the information against selected security and law
enforcement databases at DHS, including TECS and the Automated Targeting System, as well as
32

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE I-94 WEBSITE SUBMISSION, DHS/CBP/PIA-016 (2013 and
subsequent updates), available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
33
See 8 U.S.C. § 1187(h)(3).

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leveraging the National Vetting Center process. CBP may use tools and search techniques to locate
publicly available information, including social media information, about the individual seeking
advance authorization to travel.34
Pre-vetting individuals for public safety and national security concerns reduces the amount
of time that officers typically spend on determining whether the individual is a match to checks
and results completed during the inspection process. CBP does not pre-vet to pre-determine a
particular processing disposition or an individual’s admissibility to the United States. CBP officers
determine an individual’s processing disposition and, as appropriate, admissibility, on a case-bycase basis and consider the totality of the facts and circumstances known to the CBP officer at the
time of inspection. CBP officers do not make any disposition determinations in advance of an
encounter with an individual.

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. ATA does not analyze any data for predictive patterns, but rather conducts name
matching and screening using existing DHS systems. ATA information stored within the
Automated Targeting System is used to compare existing information about travelers and cargo
entering and exiting the country with patterns identified as requiring additional scrutiny. The
patterns are based on CBP officer experience, trend analysis of suspicious activity, law
enforcement cases, and raw intelligence.

3.3

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

Yes. While the advance information stored in the Advanced Traveler Information System
is typically not available for access by other DHS components, all ATA information is sent to the
Automated Targeting System and may be accessed by DHS components who have appropriate
access provisions within Automated Targeting System entitlements. Furthermore, information that
is input into Unified Secondary upon the individual’s arrival at a port of entry may be accessed by
other components with proper entitlements. While the roles and responsibilities in Unified
Secondary are limited to CBP personnel only, other DHS components may create TECS lookouts
to aid in referring a traveler to secondary inspection. Furthermore, secondary inspections that result
in adverse or administrative immigration actions are automatically sent to and stored in the ICE
34

The use of publicly available information on social media platforms to grant or deny an advance authorization
complies with DHS Management Directive 110-01-011 “Privacy Policy for Operational Use of Social Media,” and
was approved by the DHS Privacy Office for certain offices within CBP.

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Enforcement Integrated Database (EID) as immigration events.35 Additionally, biometric and
associated biographic information collected during the inspection process may be searched and
enrolled in the Automated Biometric Identification System/Homeland Advanced Recognition
Technology System.36

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that CBP will conduct pre-arrival vetting checks on
individuals who do not arrive at a U.S. port of entry.
Mitigation: This risk is partially mitigated. CBP may conduct pre-arrival vetting on
individuals who never arrive in the United States since this use is consistent with current CBP
operations, such as when CBP receives advance passenger information (API) from carriers who
submit information regarding travelers intending to travel to the United States but who do not
arrive. In both these circumstances, CBP still collects information on and vets travelers to identify
public safety threats (such as wants/warrants) and national security threats (such as links to terrorist
organizations).
Privacy Risk: There is a risk that CBP will use the selfie collected by CBP OneTM for
purposes beyond identity verification and vetting for ATA determination.
Mitigation: This risk is mitigated. CBP will use the selfie photograph for five purposes:(1)
to conduct one-to-one (1:1) facial comparison against the passport photograph previously uploaded
to the ATA mobile application from the eChip; (2) to conduct (1:n) vetting against derogatory
photographic holdings for law enforcement and national security concerns as part of the ATA
vetting process; (3) to generate a new gallery of ATA participants for facial comparison when

35

The Enforcement Integrated Database is a DHS shared common database repository used by several DHS law
enforcement and homeland security applications. Enforcement Integrated Database stores and maintains information
related to the investigation, arrest, booking, detention, and removal of persons encountered during immigration and
criminal law enforcement investigations and operations conducted by ICE, USCIS, and CBP. Enforcement
Integrated Database supports ICE’s processing and removal of noncitizens from the United States. See U.S.
DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT,
PRIVACY IMPACT ASSESSMENT FOR THE ENFORCEMENT INTEGRATED DATABASE (EID),
DHS/ICE/PIA-015 (2010 and subsequent updates), available at https://www.dhs.gov/privacy-documents-ice.
36
See U.S. DEPARTMENT OF HOMELAND SECURITY, OFFICE OF BIOMETRIC IDENTITY
MANAGEMENT, PRIVACY IMPACT ASSESSMENT FOR THE AUTOMATED BIOMETRIC
IDENTIFICATION SYSTEM (IDENT), DHS/OBIM/PIA-001 (2012), available at https://www.dhs.gov/privacydocuments-office-biometric-identity-management-obim. DHS is in the process of replacing the Automated
Biometric Identification System with the Homeland Advanced Recognition Technology System as the primary DHS
system for storage and processing of biometric and associated biographic information. For more information about
the Homeland Advanced Recognition Technology System, please see U.S. DEPARTMENT OF HOMELAND
SECURITY, OFFICE OF BIOMETRIC IDENTITY MANAGEMENT, PRIVACY IMPACT ASSESSMENT FOR
THE HOMELAND ADVANCED RECOGNITION TECHNOLOGY SYSTEM (HART) INCREMENT 1,
DHS/OBIM/PIA-004 (2020), available at https://www.dhs.gov/privacy-documents-office-biometric-identitymanagement-obim.

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ATA participants arrive at a port of entry; (4) to conduct (1:n) identity verification once the
participants arrive at the port of entry; and (5) conduct (1:n) vetting against known derogatory
photographs for admissibility determination. For the selfie photograph used only for identity
verification against the traveler’s passport photograph, CBP will store this photograph in the
Automated Targeting System and Advanced Traveler Information System for the duration of the
validity of the travel authorization (generally 90 days unless granted an extension), or traveler
passport expiration date (whichever is sooner). If the photograph is a match against national
security or law enforcement derogatory information, the photograph will be saved consistent with
other law enforcement encounters for 75 years.

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.

Individuals are provided notice of use of the CBP OneTM mobile application and the
collection of information described above when the traveler receives the approval notice from
myUSCIS that explains next steps. CBP also provides notice to the individual at the time of the
electronic collection in the CBP OneTM mobile application.

4.2

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

Participating in the ATA process is entirely voluntary. Individuals do not have the right to
consent to particular uses of the information. Individuals may only choose whether or not they will
submit their information as part of this process, in order to request advance authorization to travel
to the United States. Once an individual submits their information through CBP One™, they
cannot exert control over the use of that data, aside from their ability to amend specific data
elements by accessing his or her account and submitting these data elements.

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that individuals will not understand how their information
will be used once submitted via CBP One™ to the U.S. Government.
Mitigation: This risk is partially mitigated. All information submitted to CBP via CBP
One™ is voluntarily submitted by individuals utilizing the process. CBP provides a Privacy Act
Statement at the point of collection on the CBP One™ application and is in the process of
publishing a publicly available information collection statement under the Paperwork Reduction
Act in the Federal Register. This Privacy Impact Assessment also provides a measure of notice
on the use of information collected from the traveler.

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Section 5.0 Data Retention by the Project
5.1

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

CBP collects and maintains information from various sources as part of the ATA process.
CBP stores the Form I-134 basic biographic information submitted by supporters within the
Arrival and Departure Information System consistent with its retention schedule of 75 years, and
consistent with other information received from USCIS on various immigration forms. The Arrival
and Departure Information System then passes the basic biographic information to the Advanced
Traveler Information System where it is combined with the user-submitted data from CBP One™
and stored for 15 years, consistent with the Electronic System for Travel Authorization retention
schedule (another advance travel authorization program). CBP also stores a copy of this
information within the Automated Targeting System as a copy from the Advanced Traveler
Information System for faster vetting. Records that are of law enforcement interest, such as an
ATA denial, are stored consistent with other law enforcement records for 75 years within the
Automated Targeting System Targeting Framework. Justification for a 15- and 75-year retention
period is based on CBP’s historical encounters with suspected terrorists and other criminals, as
well as the broader experience of the law enforcement and intelligence communities.
CBP OneTM is a passthrough of information and does not store any official biographic or
biometric record. The user’s biographic data, passport number, and citizenship data submitted
through the CBP One™ application is stored in a CBP-owned cloud storage solution for 365 days
for auditing purposes and reporting aggregate data for CBP leadership. CBP One™ also collects
the first and last name of the user as part of the profile creation and this information is stored
locally on the user’s device to create a user profile within CBP One™ so that the user can quickly
retrieve information for subsequent use.
For the selfie photograph used only for identity verification against the traveler’s passport
photograph, CBP will store this photograph in the Automated Targeting System and Advanced
Traveler Information System for the duration of the validity of the travel authorization (generally
90 days unless granted an extension), or traveler passport expiration date (whichever is sooner).
Photographs used for vetting to make a travel authorization determination, and new photographs
collected as part of the entry process at the port of entry, are stored for 75 years consistent with the
DHS Office of Biometric Information Management current record schedule.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk of overcollection since CBP may retain information from
USCIS about individuals who do not submit an advance travel authorization via CBP One, or
individuals who provide information through the CBP OneTM application but do not travel to the
United States.

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Mitigation: This risk is partially mitigated. Advance travel authorizations are only valid
for 90 days (unless granted an extension), or traveler passport expiration date (whichever is
sooner), after which CBP will delete selfie photographs used for identity verification. While CBP
anticipates that most travelers who are submitted as beneficiaries by a supporter using the ATA
process will complete their portion of the ATA process, it is possible that CBP will retain
information collected by USCIS about individuals who do not use the ATA process. However, this
process is consistent with CBP’s storage of other immigration forms from USCIS within the
Arrival and Departure Information System to create a person-centric record about an individual’s
immigration and border security related actions.
Privacy Risk: There is a risk that information will be retained for longer than necessary.
Mitigation: This risk is not yet mitigated. CBP is in the process of developing a records
retention schedule for ATA information in the Advanced Traveler Information System. CBP
proposes retaining information for 15 years, which is consistent with other advance travel
authorizations such as the Electronic System for Travel Authorization. This retention period is
based on CBP’s historical encounters with suspected terrorists and other criminals, as well as the
broader experience of the law enforcement and intelligence communities. If the record is linked to
active law enforcement lookout records, CBP matches to enforcement activities, and/or
investigations or cases (i.e., specific and credible threats; flights, travelers, and routes of concern;
or other defined sets of circumstances), the record will remain accessible for the life of the law
enforcement matter to support that activity and other enforcement activities that may become
related, and which are retained in TECS.

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.

The information submitted by the individual seeking advance authorization to travel is
used for vetting and may be shared, on a need to know basis or pursuant to information sharing
arrangements with other agencies at the federal, state, local, foreign, or tribal level, who, in
accordance with their responsibilities, are lawfully engaged in collecting law enforcement or
intelligence information (whether civil or criminal) and/or investigating, prosecuting, enforcing,
or implementing civil and/or criminal laws, related rules, regulations, or orders. Additionally, CBP
may share ATA information consistent with routine uses outlined in the Automated Targeting
System System of Records Notice and other Privacy Act conditions for disclosure.

6.2

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

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Disclosure of ATA data to an agency outside of DHS must be compatible with the
purposes for which the data was collected and authorized under the Privacy Act of 1974, 5 U.S.C.
§ 552a(b)(3), specifically the routine uses set forth in the Automated Targeting System System of
Records Notice or as otherwise permitted by the Privacy Act.

6.3

Does the project place limitations on re-dissemination?

Information that is disclosed from ATA to another agency may not be disseminated to third
parties without the written consent of CBP.

6.4

Describe how the project maintains a record of any disclosures

External sharing is appropriately logged pursuant to subsection (c) of the Privacy Act,
which requires the Department to maintain a log of when records have been shared outside of
DHS.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk that the data used for the ATA process and stored in CBP
systems such as the Advanced Traveler Information System will be shared under inappropriate
circumstances and inconsistent with the original purpose of collection.
Mitigation: This risk is partially mitigated. Absent any legal prohibitions, CBP may share
information from the Advanced Traveler Information System with other DHS or component
personnel who have an authorized purpose for accessing the information in performance of his or
her duties, possess the requisite security clearance, and assure adequate safeguarding and
protection of the information. In addition, CBP may share information externally consistent with
the Privacy Act and routine uses published in the Automated Targeting System System of Records
Notice, and consistent with DHS policy and existing memoranda of understanding (MOU),
including setting forth the restrictions on and conditions of use; securing, storing, handling, and
safeguarding requirements; and controls on further dissemination.
Privacy Risk: There is a risk that the data shared with an agency on a need-to-know basis
or pursuant to an information sharing arrangement may be further shared with a third-party agency.
Mitigation: This risk is partially mitigated. When information is shared with an agency,
specific re-dissemination language will be in the information sharing arrangement that limits thirdparty disclosure without prior authorization from CBP.

Section 7.0 Redress
7.1

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

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In the event that an individual is not authorized to travel under this process, they may still
seek entry through another process, including by filing a request for consideration of parole with
USCIS or applying with the Department of State to obtain a visa. Due to the secure nature of the
vetting and screening process, CBP cannot offer additional information to individuals about the
process or provide details about the status and/or result of a beneficiary’s travel authorization
review. If travel authorization is denied, CBP is unable disclose information as to why the denial
occurred. Individuals with questions regarding the ATA process may contact the DHS Traveler
Redress Inquiry Program (TRIP) at https://www.dhs.gov/dhs-trip. For information about CBP’s
facial comparison program generally, please visit https://biometrics.cbp.gov/ or review the publicfacing Privacy Impact Assessment for the Traveler Verification Service.37
Individuals seeking notification of and access to information contained in CBP holdings,
or seeking further information related to his or her secondary inspection, may gain access to certain
information by filing a Freedom of Information Act (FOIA) request with CBP at
https://foia.cbp.gov/palMain.aspx, or by mailing a request to:
U.S. Customs and Border Protection (CBP)
Freedom of Information Act (FOIA) Division
1300 Pennsylvania Avenue NW, Room 3.3D
Washington, D.C. 20229
Fax Number: (202) 325-1476
U.S. citizens, lawful permanent residents, and individuals who have records covered under the
Judicial Redress Act (JRA) may file a Privacy Act request to access their information.
All Privacy Act and Freedom of Information Act requests must be in writing and include
the requestor’s daytime telephone number, email address, and as much information as possible of
the subject matter to expedite the search process. Requests for information are evaluated by CBP
to ensure that the release of information is lawful; will not impede an investigation of an actual or
potential criminal, civil, or regulatory violation; and will not reveal the existence of an
investigation or investigative interest on the part of DHS or another agency.

7.2

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

CBP’s TVS is an accredited information technology system consisting of a group of similar systems and
subsystems that support the core functioning and transmission of data between CBP applications and partner
interfaces. Since early 2017, CBP has used the TVS as its backend matching service for all biometric entry and exit
operations that use facial recognition, regardless of air, land, or sea. See U.S. DEPARTMENT OF HOMELAND
SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT ASSESSMENT FOR THE
TRAVELER VERIFICATION SERVICE, DHS/CBP/PIA-056 (2018), available at https://www.dhs.gov/privacydocuments-us-customs-and-border-protection.
37

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Once arriving at a port of entry, all ATA individuals will be referred for secondary
inspection. Individuals may correct inaccurate or erroneous information directly with the
processing CBP officer who will correct the information in Unified Secondary, at the time of
encounter and throughout the secondary inspection process.
Any individual who believes that CBP’s actions are the result of incorrect or inaccurate
information may request information about his or her records pursuant to procedures provided by
the Freedom of Information Act. U.S. citizens, lawful permanent residents, and individuals who
have records covered under the Judicial Redress Act who believe that CBP’s actions are the result
of incorrect or inaccurate information may request correction of that data under the amendment
provisions of the Privacy Act by writing to the above address. The CBP Privacy Division reviews
all requests for correction and amendment regardless of status.
Travelers may also contact the DHS Traveler Redress Inquiry Program (TRIP) at 601 South
12th Street, TSA-901, Arlington, VA, 22202-4220 or online at www.dhs.gov/trip. Individuals
making inquiries should provide as much identifying information as possible to identify the
record(s) at issue.

7.3

How does the project notify individuals about the procedures for
correcting his or her information?

Individuals are notified of the procedures for correcting their information through the
System of Records Notices describing each of the underlying systems from which CBP accesses
information. This Privacy Impact Assessment also serves as notification. Additionally, signage
and tear sheets at ports of entry provide information on how to contact DHS TRIP. Travelers may
also request information from an on-site CBP officer.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that travelers will not know how to request redress.
Mitigation: This risk is mitigated. This Privacy Impact Assessment provides information
on how to request access and amendments to information within CBP holdings. Additionally, CBP
officers located at ports of entry inform travelers verbally and through tear sheets on how they can
challenge a determination and request access to the information that CBP used to make a
determination. Travelers who wish to access information about themselves or challenge a
determination can submit a Freedom of Information Act request to CBP or a DHS TRIP request
to the addresses above. Additionally, U.S. citizens, lawful permanent residents, and individuals
who have records covered under the Judicial Redress Act, may submit a Privacy Act Amendment
request to CBP.

Section 8.0 Auditing and Accountability

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8.1

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

All CBP systems used for the ATA process have role-based access that is granted to users
who have a demonstrated need to know. CBP secures its data by complying with the requirements
of DHS information technology security policy, particularly the DHS Sensitive Systems Policy
Directive 4300A.38 This handbook establishes a comprehensive program to provide complete
information security, including directives on roles and responsibilities, management policies,
operational policies, technical controls, and submission rules. CBP periodically evaluates these
systems to ensure that they comply with these security requirements. Each system provides audit
trail capabilities to monitor, log, and analyze system transactions as well as actions and system
accesses of authorized users. CBP periodically conducts reviews for compliance within the
program and between external partners to ensure that the information is used in accordance with
the stated acceptable uses documented in information sharing agreements, and other technical and
business documentation.

8.2

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

CBP system access is not activated for any user without completion of the CBP Security
and Privacy Awareness course, which is required to be completed on an annual basis. This course
presents Privacy Act responsibilities and agency policy regarding the security, sharing, and
safeguarding of both official information and personally identifiable information. The course also
provides information regarding sharing, access, and other privacy controls. CBP updates this
training regularly.

8.3

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

CBP secures information in compliance with the DHS Sensitive Systems Policy Directive
4300A and corresponding implementation Handbook. This handbook establishes a comprehensive
program, consistent with federal law and policy, to provide complete information security,
including directives on roles and responsibilities, management policies, operational policies, and
submission rules. To gain access to CBP systems, a user must not only have a need to know but
must also have an appropriate background clearance and completed annual privacy training. A
supervisor submits the request to the Office of Information and Technology (OIT) at CBP
indicating the individual has a need to know for official purposes. The Office of Information and
38

See DHS 4300A SENSITIVE SYSTEMS HANDBOOK, available at https://www.dhs.gov/publication/dhs4300a-sensitive-systems-handbook.

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Technology verifies that the necessary background check and privacy training has been completed
prior to issuing a new internal user account. Internal user accounts are reviewed annually to ensure
that these standards are maintained. These rules also require a periodic assessment of technical,
administrative, and managerial controls to enhance data integrity and accountability. System users
must sign statements acknowledging that they have been trained and understand the security
aspects of the systems to which they gain access.

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?

Any information sharing agreements for this data will define the nature of access, the scope
of information subject to the sharing agreement, and privacy, security, safeguarding, and other
requirements. All CBP information sharing agreements are reviewed by the CBP Privacy Officer
and the CBP Office of Chief Counsel in accordance with existing CBP and DHS policy.

Contact Official
Matthew Davies
Executive Director
Admissibility and Passenger Programs
Office of Field Operations
U.S. Customs and Border Protection

Responsible Official
Debra L. Danisek
CBP Privacy Officer
Privacy and Diversity Office
U.S. Customs and Border Protection
privacy.cbp@cbp.dhs.gov

Approval Signature
Original, signed copy on file with the DHS Privacy Office.
________________________________
Lynn Parker Dupree

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Chief Privacy Officer
U.S. Department of Homeland Security
(202) 343-1717

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APPENDIX A
Citizens from the following countries determined by the Secretary of the Department of
Homeland Security, and their qualified immediate family members, are eligible to participate in
the ATA process:
1. Venezuela

(eligible on October 12, 2022)