Dhs/cbp/pia-068

Privacy Impact Assessment
for

CBP One™
DHS Reference No. DHS/CBP/PIA-068
February 19, 2021

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Abstract
The U.S. Department of Homeland Security (DHS), U.S. Customs and Border Protection
(CBP), launched a new public-facing application, CBP One™, to provide the public a single portal
to a variety of CBP services. The application is available on both web and mobile devices. CBP
One™ will eventually replace and upgrade existing CBP public-facing mobile applications to
improve user interaction and services. CBP One™ includes different functionality for travelers,
importers, brokers, carriers, International Organizations, and other entities under a single
consolidated log-in and uses guided questions to help users determine the correct services, forms,
or applications needed. CBP is conducting this Privacy Impact Assessment (PIA) to address
privacy risks in the deployment and use of the CBP One™ mobile application.

Introduction
On October 28, 2020, CBP launched the CBP One™ application. CBP One™ is an
application that serves as a single portal to a variety of CBP services. Through a series of guided
questions, the application will direct each type of user to the appropriate services based on their
needs.
CBP One™ is available for Android and iOS mobile devices in the Google Play or iTunes
mobile application stores, as well as on the web at CBP One
(dhs.gov). Users must create a new or open an existing
Login.Gov 1 account in order to access CBP One™. Login.Gov
ensures a secure connection and identity verification for CBP
One™ users. To register with Login.gov, users have to provide
an email address and a phone number and create a password.
Login.gov does not share any information provided by the user
with CBP. Each time a user launches CBP One™, a notification
displaying the CBP Privacy Policy will appear and users must
consent to it prior to using the mobile application.
Once the user has logged in via Login.gov and
consented to the privacy policy, the landing page will launch
which permits the user to select from different options that
describe the individual’s reason for using CBP One™. CBP
One™ will display different functions based on the user’s
selections. For some functions, users are able to input

Figure 1: CBP One Login Screen

See GENERAL SERVICES ADMINISTRATION, PRIVACY IMPACT ASSESSMENT FOR LOGIN.GOV (2020), available at
https://www.gsa.gov/reference/gsa-privacy-program/privacy-impact-assessments-pia.

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information for themselves, as well as for others. This makes it easier for groups to submit
information, and streamlines CBP’s vetting and inspection processes.
Currently, CBP One™ is available for brokers/carriers/forwarders to make appointments
for the inspection of perishable cargo and travelers to apply for and view their I-94s. In addition,
CBP One™ is available to International Organizations, 2 authorized by persons asserting
enrollment in the Migrant Protection Protocols (MPP) 3 Program, to submit biometric and
biographic information to verify enrollment in MPP on their behalf.
Eventually, aircraft operators, bus operators, seaplane pilots, commercial truck drivers,
vessel operators, or agents will be able to use CBP One™. CBP will add appendices to this PIA to
describe new functions as they are launched in the application. Depending on the function, CBP
may also publish standalone, function-specific PIAs to fully analyze the risks and mitigations CBP
has put in place to protect individual privacy.
Travelers
Individuals traveling into or exiting the United States will be able to use CBP One™ to
inform CBP of their arrival and departure consistent with applicable laws. Additionally, travelers
will be able to use CBP One™ to apply for certain CBP benefits, such as membership into CBP’s
Trusted Traveler Program, as well as view some information CBP may maintain on the traveler.
At launch, the I-94 functionality in CBP One™ mirrored the I-94 website functionality. 4
This allows nonimmigrant aliens to apply for a provisional I-94, pay in advance of arrival for an
I-94, retrieve their most recent I-94, view their travel history, and check their authorized period of
stay on any active I-94. By Summer 2022, CBP will pilot a new Self-Reporting Mobile Exit
feature. This new feature will allow some nonimmigrant aliens to self-report their exit from the
United States at certain ports of entry on the Northern Border. Appendix A of this PIA describes

An International Organization is an organization that established a treaty or other instrument governed by
international law and possessing its own international legal personality, such as the United Nations (UN), the World
Health Organization (WHO), and North Atlantic Treaty Organization (NATO). For the purpose of this PIA,
International Organizations have established roles supporting the Government of Mexico to provide services to
undocumented individuals under the Migrant Protections Protocol (MPP).
3
The MPP are a U.S. Government action whereby certain foreign individuals entering or seeking admission to the
United States from Mexico – illegally or without proper documentation – may be returned to Mexico and wait
outside of the United States for the duration of their immigration proceedings, where Mexico will provide them with
all appropriate humanitarian protections for the duration of their stay. Additional information is available at
https://www.dhs.gov/news/2019/01/24/migrant-protection-protocols. Appendix C of this PIA further outlines the
implementation of MPP through CBP One™.
4
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR THE I-94 WEBSITE APPLICATION, DHS/CBP/PIA-016 (2013 and subsequent updates), available at
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
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the I-94 functionality of CBP One™ and CBP will publish a standalone, function-specific PIA
before making the Self-Reporting Mobile Exit feature active.
Also by Fall 2022, CBP plans on moving the standalone CBP ROAM™ mobile application
under the CBP One™ umbrella. CBP ROAM™ permits small pleasure boat operators along the
Northern Border to report their arrival into United States. In the future, CBP ROAM™ will be
removed from the Google Play and iOS mobile application stores, and travelers will have to use
CBP One™ to complete the same transactions. CBP will update Appendix A of this PIA and
publish a standalone, function-specific PIA once this offshore arrival reporting functionality is
available in CBP One™.
Broker/Carrier/Forwarder Agents
The Inspection Appointment request feature allows brokers/carriers/forwarders to schedule
and check the appointment status of an inspection of commercial vessels or for cargo entering the
United States. CBP One™ streamlines the scheduling process, which previously required multiple
phone calls and exchange of information between brokers/carriers/forwarders and CBP officers or
agriculture specialists. Using CBP One™, brokers/carriers/forwarders create a profile that includes
contact and port of entry information. Users then request a specific day and time for inspection of
their vessel or goods by a CBP officer or agriculture specialist. CBP officers or agriculture
specialists use a dashboard outside of CBP One™ to view the requests and assign inspection times.
The CBP officer or agriculture specialist can also use the dashboard to communicate with the
broker/carrier/forwarder, using CBP One™, in order to gain any additional information. Finally,
brokers/carriers/forwarders are able to cancel and reschedule an inspection request through CBP
One™. CBP One™ inspections of cargo can also be accessed via a desktop application. In the
future, CBP plans to incorporate all cargo into the desktop application.
Operators
Operators are representatives of a company, such as bus drivers and plane pilots, who are
authorized to use CBP One™ to submit manifest information to CBP. Sea, land, and air operators
will be able to use CBP One™ to submit information to CBP on behalf of consenting travelers
through applications, such as the I-94 mobile application. Operators will use the application to
gather information from travelers in order to bulk submit information to CBP. Operator capabilities
will not be available in CBP One™ at launch. Once operator functionality launches, CBP will
create an appendix to this PIA and, as necessary, publish a standalone PIA Update documenting
the new features.
International Organizations
CBP has formed partnerships with International Organizations to assist aliens seeking
admission into the United States. Access to the International Organization functionality within

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CBP One™ is limited to International Organizations identified by the United States Department
of State (DoS) as having established roles supporting the Government of Mexico to provide
services to MPP enrollees. If the user is not a verified International Organization, the individual
will not see the International Organization persona in the list of options on the CBP One™
homepage. Appendix C of this PIA provides additional guidance on the use and functionality of
the International Organization feature and CBP is developing a standalone, function-specific PIA
for the MPP program.
Information Collected
The information users provide to CBP depends on the function of CBP One™ that they are
using. For example, individuals using CBP One™ to report their travel into and out of the United
States have to provide more information than users scheduling agriculture inspection
appointments. Users will have to provide basic biographic information, such as first and last name,
contact information, and email address, in order to create a Login.gov account and use the
application. Regardless of the function, CBP One™ does not store any information locally on the
device. CBP pushes all information collected through CBP One™ to back-end systems associated
with the functions the user is using. For example, CBP will store information related to I-94
information submitted through CBP One™ in CBP’s I-94 databases.
Compliance Framework
In its initial phase, CBP One™ is operational for users to schedule an agricultural
inspection or apply for an I-94 prior to arrival. CBP One™ will continue to expand to become the
unified mobile portal for public transactions with CBP. CBP is conducting this overarching PIA
to describe the risks and mitigations associated with CBP One™; however, due to broad and
disparate functions contemplated for CBP One™, CBP will conduct standalone, function-specific
PIAs for each function as necessary. CBP will add or update the Appendices to this PIA as new
functions are developed to ensure transparency regarding all publicly available CBP mobile
applications.

Fair Information Practice Principles (FIPPs)
The Privacy Act of 1974 5 articulates concepts of how the federal government should treat
individuals and their information and imposes duties upon federal agencies regarding the
collection, use, dissemination, and maintenance of personally identifiable information. The
Homeland Security Act of 2002 Section 222(2) states that the Chief Privacy Officer shall assure

5

5 U.S.C. § 552a.

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that information is handled in full compliance with the fair information practices as set out in the
Privacy Act of 1974. 6
In response to this obligation, the DHS Privacy Office developed a set of Fair Information
Practice Principles (FIPPs) from the underlying concepts of the Privacy Act to encompass the full
breadth and diversity of the information and interactions of DHS. 7 The FIPPs account for the
nature and purpose of the information being collected in relation to DHS’s mission to preserve,
protect, and secure.
DHS conducts Privacy Impact Assessments on both programs and information technology
systems, pursuant to the E-Government Act of 2002, Section 208 8 and the Homeland Security Act
of 2002, Section 222. 9 Given that CBP One™ is a portal rather than a particular information
technology system, this PIA is conducted as it relates to the DHS construct of the FIPPs. This PIA
examines the privacy impact of CBP One™ as it relates to the FIPPs.

1. Principle of Transparency
Principle: DHS should be transparent and provide notice to the individual regarding its
collection, use, dissemination, and maintenance of PII. Technologies or systems using PII must be
described in a SORN and PIA, as appropriate.
CBP One™ is a publicly available mobile application available for Android and iOS
mobile devices in the Google Play or iTunes mobile application stores. To promote transparency
and provide notice to the public of this new mobile portal to CBP services, CBP published a press
release when CBP One™ was launched to the public. 10 The release detailed the functions available
at launch as well as the functions that CBP plans to roll out in the future. CBP is also working with
industry to provide additional information about CBP One™. CBP will continue to provide
information to the public through the use of flyers and outreach to industry groups. CBP may
conduct targeted outreach for specific functions, and may conduct standalone, function-specific
PIAs for new functions as necessary for additional transparency.
There is no privacy risk to transparency; CBP One™ is public-facing and voluntarily
available for the public to use.

6 U.S.C. § 142(a)(2).
U.S. DEPARTMENT OF HOMELAND SECURITY, PRIVACY POLICY GUIDANCE MEMORANDUM 2008-01/PRIVACY
POLICY DIRECTIVE 140-06, THE FAIR INFORMATION PRACTICE PRINCIPLES: FRAMEWORK FOR PRIVACY POLICY AT
THE DEPARTMENT OF HOMELAND SECURITY (2008), available at https://www.dhs.gov/privacy-policy-guidance.
8
44 U.S.C. § 3501 note.
9
6 U.S.C. § 142.
10
See U.S. CUSTOMS AND BORDER PROTECTION, CBP ONE™ MOBILE APPLICATION, available at
https://www.cbp.gov/about/mobile-apps-directory/cbpone.
6
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2. Principle of Individual Participation
Principle: DHS should involve the individual in the process of using PII. DHS should, to
the extent practical, seek individual consent for the collection, use, dissemination, and
maintenance of PII and should provide mechanisms for appropriate access, correction, and
redress regarding DHS’s use of PII.
Anyone may voluntarily download CBP One™ from the mobile application store on his or
her mobile device. While CBP One™ is limited in its initial functionality, it is available for any
traveler or entity that needs to interact with CBP, so long as the mobile application supports the
function that the user is trying to complete.
In addition, CBP One™ contains a privacy policy that appears every time a user logs in.
Users must consent to the terms of using the application prior to being authorized to use it. CBP
reserves the right to make changes to the privacy policy by giving notice to its travelers on the
CBP One™ Mobile App privacy policy page, and by ensuring protection of PII in all cases. CBP
strongly recommends visiting the CBP One™ Mobile App privacy policy page, and referring to
the dates of the modification. Additionally, CBP will place a banner notice on the app landing page
to notify users that CBP has updated the privacy policy. Depending on the functionality, if
applicable, CBP One™ also uses “just-in-time” notifications that require users consent before the
application can access camera or GPS functions, for example.
Some functions of CBP One™ allow users to submit information on behalf of other people.
This may include a family member submitting information on behalf of another, to the extent
authorized by law. For example, a parent could submit an exit or request travel history on behalf
of his or her minor child. In other functions an operator or International Organization collect
information from individuals and submit that information to CBP, through CBP One™. For
example, a bus operator may collect information from travelers and submit that information to
CBP through CBP One™ in order to report the traveler’s entry or an International Organization
may collect information on behalf of aliens seeking admission to the United States, typically as
part of a formalized program such as MPP. International Organizations and Operators are
responsible for notifying individuals about information collected and submitted to CBP through
CBP One™.
Because CBP One™ does not store any information, there are no records to correct or
amend. If users submit incorrect information through CBP One™ they can resubmit new
information or contact the CBP INFO Center online or by calling 1-877-CBP-5511 to determine
how to update their submission. Additionally, travelers may request information about records
contained in the source systems that CBP One™ populates through procedures provided by the
Freedom of Information Act (FOIA) (5 U.S.C. § 552) and the access provisions of the Privacy Act
of 1974 (5 U.S.C. § 552a(d)) online at https://foia.cbp.gov/palMain.aspx or by writing to:

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CBP FOIA Headquarters Office
U.S. Customs and Border Protection
FOIA Division
90 K Street NE, 9th Floor
Washington, DC 20002
Fax Number: (202) 325-0230
When seeking records, the request must conform to Part 5, Title 6 of the Code of Federal
Regulations. An individual must provide his or her full name, current address, and date and place
of birth. The individual must also provide:
•
•
•

An explanation of why the individual believes DHS would have information on him or
her;
Details outlining when the individual believes the records would have been created;
and
If the request is seeking records pertaining to another living individual, a statement
from that individual certifying his or her agreement for access to his or her records.

The request must include a notarized signature or be submitted pursuant to 28 U.S.C. § 1746,
which permits statements to be made under penalty of perjury as a substitute for notarization.
Without this information, CBP may not be able to conduct an effective search and the request may
be denied due to lack of specificity or lack of compliance with applicable regulations. Although
CBP does not require a specific form, guidance for filing a request for information is available on
the DHS website at http://www.dhs.gov/file-privacy-act-request and at http://www.dhs.gov/filefoia-overview.
Privacy Risk: There is a risk that a user could submit information about another
individual(s), without receiving prior consent from the individual(s).
Mitigation: This risk is partially mitigated. Although CBP cannot prevent users from
submitting information for other users, there is no discernable benefit for a user to do so.
Additionally, the user would have to have access to another person’s biographic information and
in some cases, travel documents. Some functions of CBP One™, like the I-94 mobile application,
also require users to submit photographs of themselves and co-travelers. CBP is able to verify if
the photograph is of a “live” person; if it is not, the transaction cannot proceed.
In addition, specific privacy risks related to individual participation will be addressed in
standalone, function-specific PIAs.

3. Principle of Purpose Specification
Principle: DHS should specifically articulate the authority which permits the collection of
PII and specifically articulate the purpose or purposes for which the PII is intended to be used.

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CBP One™ allows users to interact with CBP for a variety of purposes. Regardless of
function, users will have to provide basic biographic and contact information in order to use the
application. Brokers/carriers/forwarders have to submit business information, such as company
name and importer ID, in addition to the user’s own biographic information, such as name and
email address, in order to schedule inspections. CBP One™ users reporting exit and entry
information will provide additional biographic information that CBP will use to verify identity and
identify derogatory information. With user consent, CBP One™ may also capture geolocation
information from users’ devices. Different functions may also require users to submit “live”
photographs of themselves. The standalone, function-specific PIAs will fully discuss the
information CBP uses to perform the required function.
CBP One™ allows users to perform a variety of functions. Because the profile creation is
done through Login.Gov, CBP One™, as an umbrella application, does not store information on
users. Consistent with the Import Information System SORN, 11 brokers/carriers/forwarders can
submit information to and interact with CBP to schedule cargo inspections. CBP’s Border Crossing
Information (BCI) 12 and Arrival and Departure Information System (ADIS) 13 SORNs govern the
information CBP One™ users provide when attempting to enter and exit the United States. CBP’s
Automated Targeting System (ATS), 14 Border Patrol Enforcement Records (BPER), 15 and the
U.S. Customs and Border Protection TECS 16 SORNs govern the information undocumented
individuals provide through CBP One™ to verify their enrollment in MPP.
Specific privacy risks related to purpose specification will be addressed in standalone,
function-specific PIAs.

4. Principle of Data Minimization
Principle: DHS should only collect PII that is directly relevant and necessary to
accomplish the specified purpose(s) and only retain PII for as long as is necessary to fulfill the
specified purpose(s). PII should be disposed of in accordance with DHS records disposition
schedules as approved by the National Archives and Records Administration (NARA).
See DHS/CBP-001 Import Information System, 81 FR 48826 (July 26, 2016), available at
https://www.dhs.gov/system-records-notices-sorns.
12
See DHS/CBP-007 Border Crossing Information (BCI), 81 FR 89957 (December 13, 2016), available at
https://www.dhs.gov/system-records-notices-sorns.
13
See DHS/CBP-021 Arrival and Departure Information System (ADIS), 80 FR 72081 (November 18, 2015),
available at https://www.dhs.gov/system-records-notices-sorns.
14
See DHS/CBP-006 Automated Targeting System (ATS), 80 FR 13407 (March 13, 2015), available at
https://www.dhs.gov/system-records-notices-sorns.
15
See DHS/CBP-023 Border Patrol Enforcement Records (BPER), 81 FR 72601 (October 20, 2016), available at
https://www.dhs.gov/system-records-notices-sorns.
16
See DHS/CBP-011 U.S. Customs and Border Protection TECS, 73 FR 77778 (December 19, 2009), available at
https://www.dhs.gov/system-records-notices-sorns.
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The retention of information CBP collects through CBP One™ depends on the function
the individual is using. CBP uses information collected through CBP One™ to populate existing
CBP systems. For example, information provided by brokers/carriers/forwarders to schedule
inspections is stored in a database within the Automated Commercial Environment for 1 year in
accordance with the Import Information System SORN. Whereas information used to report a
traveler’s exit from the United States may be stored in ADIS for 75 years.
Specific privacy risks related to data minimization will be addressed in standalone,
function-specific PIAs, including the relevant data retention period for the information. No
information is stored locally on the user’s device or in the CBP One™ application itself.

5. Principle of Use Limitation
Principle: DHS should use PII solely for the purpose(s) specified in the notice. Sharing PII
outside the Department should be for a purpose compatible with the purpose for which the PII was
collected.
CBP uses Login.gov to provide a secure and credentialed way for CBP One™ users to
access the application and its different functions. CBP One™ allows users a single easy to use
portal through which to conduct a variety of transactions with CBP. CBP uses information
provided by brokers/carriers/forwarders to schedule inspection appointments and request
additional information. CBP uses other traveler-provided information in order to vet travelers,
update systems, and display relevant information to travelers. CBP uses geolocation information
to determine whether functions, such as reporting exit and arrival, can be accessed by the user, and
to confirm whether or not the individual is in the 1-mile pertinent radius reporting requirement. 17
CBP uses photographs submitted by users in order to validate identity and that the person is “live”,
employing liveness detection capabilities. CBP will publish standalone, function-specific PIAs for
certain functions within CBP One™.
CBP may share information collected through CBP One™ both inside and outside of DHS
consistent with applicable law and policy. However, no sharing will come directly from CBP
One™. Any sharing is done from the system in which the information resides, pursuant to the
applicable SORNs that govern that system and associated information sharing arrangements.
Primarily, CBP would share information collected through CBP One™ for vetting purposes.
Standalone, function-specific PIAs will fully discuss function-specific sharing.
Privacy Risk: There is risk that geolocation information (e.g., latitude, longitude) collected
from users of certain CBP One™ functions may be used by CBP to conduct surveillance on
travelers or to track traveler’s movement.
For inbound vessels, CBP does not allow travelers to report their arrival until they are within 1 mile of the U.S.
border. Similarly, CBP requires travelers to be at least 1 mile outside of the U.S. border to report their exit.

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Mitigation: This risk is fully mitigated. The geolocation information collected from CBP
One™ users will not be used to conduct surveillance or track traveler’s movement. CBP does not
track the location of the traveler’s device beyond the time of submission of the data. At the time
the user submits his or her exit or entry, the device’s GPS is pinged by CBP One™ and the latitude
and longitude coordinates are sent to CBP. The GPS ping is only collected at the exact time the
user pushes the submit button and is used to confirm the traveler’s device is in some cases inside
a certain CBP-defined radius or outside the United States. The latitude and longitude information
captured is not visible to CBP Officers or Agents. CBP collects the latitude and longitude
information from the GPS ping and uses this information for analytical purposes (e.g., to determine
that the individual is in the 1-mile radius pertinent reporting requirement for the report of arrival
of pleasure boats through CBP ROAM or outside of the United States for exit).
In addition, any specific privacy risks related to use limitation will be addressed in any
standalone, function-specific PIAs.

6. Principle of Data Quality and Integrity
Principle: DHS should, to the extent practical, ensure that PII is accurate, relevant, timely,
and complete, within the context of each use of the PII.
CBP One™ collects information directly from users who are voluntarily using the
application. A user must consent to a Privacy Policy each time CBP One™ launches. Users can
manually enter information or use their device’s camera to scan the Machine-Readable Zone of a
travel document, which will prepopulate information into CBP One™. Depending on the function,
CBP may check information submitted by the user against CBP holdings to verify that the
information matches already existing information. Users have an incentive to provide CBP with
accurate information because users have chosen to voluntarily interact with CBP through CBP
One™ and are seeking some form of service from CBP. Some users may submit information on
behalf of others; for example, a family member submitting information for another family member,
to the extent authorized by applicable law and policy. Additionally, operators may use CBP One™
to submit arrival and departure information for their passengers and crew to the extent authorized.
Operators who submit information about travelers to CBP through CBP One™ are responsible for
notifying travelers about their collection and sharing of the information with CBP. Operators
generally provide this notice during their ticketing process. International Organizations provide
notice to individuals before submitting information to CBP on their behalf.
In some cases, CBP One™ obtains consent from users to view GPS location at time of
submission. This ensures that entries and exits are accurately submitted and prevents users from
attempting to claim they have departed the United States when they are still in the United States.
Additionally, for some functions CBP requires users to submit a photograph of the person whose
information is being captured by CBP One™. CBP uses photographs submitted by its users to

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validate identity, match against CBP holdings, and determine whether the photograph is “live”.
The liveness detection capabilities provide validation that an individual is present at the time of
submission.
people.

Privacy Risk: There is risk that users will submit inaccurate information about other

Mitigation: This risk is fully mitigated. Although CBP cannot prevent users from
submitting inaccurate information on behalf of themselves or other people, CBP can verify the
information before retaining it as accurate. It is unlikely that a user will submit inaccurate
information on about another person. Primarily, because there is no benefit in submitting
inaccurate information through CBP One™. In some cases, the submission of the inaccurate
information could subject the user to monetary or legal penalties. CBP verifies that the biographic
information is correct and depending on the function can verify the identity of a person and their
location.
In addition, any specific privacy risks related to data quality and integrity will be addressed
in any standalone, function-specific PIAs.

7. Principle of Security
Principle: DHS should protect PII (in all forms) through appropriate security safeguards
against risks such as loss, unauthorized access or use, destruction, modification, or unintended or
inappropriate disclosure.
The CBP One™ mobile application uses Login.gov to manage users’ authentication by
allowing users to sign in with an email address, password, and multi-factor method, and conduct
identity proofing by verifying an individual’s asserted identity. Login.gov ensures a secure
connection and identity verification when using the CBP One™ mobile application. Individuals
with a Login.gov account can sign into multiple government websites (including CBP One™) with
the same email address and password. Login.gov does not share any information provided by the
user with CBP.
No information is stored locally on the user’s device or in the CBP One™ application itself.
The retention of information CBP collects through CBP One™ depends on the function the user
is using. CBP uses information collected through CBP One™ to populate existing CBP systems.
In turn, the security controls of those systems protect the information. For example, information
provided by brokers/carriers/forwarders to schedule inspections is stored in a database within the
CBP Amazon Web Services (AWS) Cloud East (CACE) and is protected by the CACE security
controls. Additionally, CBP has analyzed the application to ensure that information is sent only to
CBP and the application can only access the information necessary to complete the functions.

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8. Principle of Accountability and Auditing
Principle: DHS should be accountable for complying with these principles, providing
training to all employees and contractors who use PII, and should audit the actual use of PII to
demonstrate compliance with these principles and all applicable privacy protection requirements.
CBP employee access to the CBP One™ system is limited to users from CBP’s Office of
Information Technology (OIT) in order to perform application updates and correct any issues. CBP
One™ only stores the users Login.gov email address locally onto the user’s device. All other
information submitted by the user through CBP One™ is sent to existing CBP source systems.
The CBP source systems where information is stored maintain their own auditing and
accountability capabilities that will be more fully explained in the appendices as functions launch,
as well as in any standalone, function-specific PIAs. Further, all CBP employees are required to
complete the DHS Security Awareness Training Course and privacy training which explains how
to properly handle and protect PII.

Conclusion
The CBP One™ mobile application is a secure, mobile portal for the public to conduct
various transactions with CBP. In its initial phase, CBP One™ is operational for users to schedule
an agricultural inspection or report their departure from the United States, in accordance with law.
CBP One™ will continue to expand to become the unified mobile portal for public transactions
with CBP. CBP conducted this overarching PIA to describe the risks and mitigations associated
with CBP One™; however, due to broad and disparate functions contemplated for CBP One™,
CBP will also conduct standalone, function-specific PIAs for certain privacy-sensitive functions.
CBP will add links and summaries of each new functional PIA to the Appendices as they are
published to ensure transparency on all publicly available CBP mobile applications.

Responsible Official

Jody Hardin
Director, Strategic Transformation Office, Office of Field Operations
U.S. Customs and Border Protection
U.S. Department of Homeland Security
Debra L. Danisek
CBP Privacy Officer, Privacy and Diversity Office
U.S. Customs and Border Protection
U.S. Department of Homeland Security
Privacy_CBP@cbp.dhs.gov

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Approval Signature
Original, signed copy on file with the DHS Privacy Office.
_______________________________
James Holzer
Acting Chief Privacy Officer
U.S. Department of Homeland Security
(202) 343-1717

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APPENDIX A: Travelers
Updated April 25, 2022

1.

I-94 Mobile

I-94 Mobile is function of CBP One™ and offers the same features as the current CBP I94 website (i.e., allows nonimmigrant aliens to apply for a provisional I-94, pay in advance of
arrival for an I-94, retrieve their most recent I-94, view their travel history, and check their
authorized period of stay on any active I-94). I-94 Mobile provides the convenience to capture
travel document information via an optical character recognition scan to auto-populate the
information into the travel document fields when adding one’s travel document information.
Additionally, I-94 Mobile will provide a traveler the ability to self-report the traveler’s exit
from the United States. CBP plans to pilot the self-reporting exit feature in Spring 2021, at select
locations along the Northern Border. The population that can volunteer to use the I-94 Mobile
features for self-reporting departures is limited to I-94 travelers who have come temporarily to the
United States and are exiting the United States at the Pacific Highway and Peace Arch Border
Crossing located in Blaine, Washington; the Champlain-St. Bernard de Lacolle Border Crossing
located in Champlain, New York; and the Ambassador Bridge and Detroit-Windsor Tunnel located
in Detroit, Michigan. CBP is conducting the pilot at these locations on the Northern Border due to
CBP’s partnership with the Canadian Border Services Agency (CBSA). If successful, CBP hopes
to expand the Self-Reporting Mobile Exit (SRME) function of I-94 Mobile to the Southern Border
to increase the accuracy of CBP exit records. CBP will publish a standalone, function-specific PIA
that discusses the SRME function in more detail and also update the existing I-94 PIA series to
include the CBP One™ mobile application as a way in which individuals can apply for and check
their I-94s.
2.

Reporting Offsite Arrival-Mobile (ROAM)

The ROAM mobile functionality is embedded into the CBP One™ mobile application and
provides travelers arriving to the United States with an option to voluntarily self-report their arrival
to CBP. In addition, the ROAM mobile functionality will automate existing manual data entry and
law enforcement queries for CBP and provide a more sophisticated capability for conducting a
remote inspection via video conference. This function will not be available at launch of CBP
One™; CBP will publish a standalone, function-specific PIA to discuss the privacy risks and
mitigations thoroughly. CBP will update this Appendix when the standalone PIA is published.

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3.

Advance Information for Certain Undocumented Individuals, including
Individuals with Advance Authorization to Travel to the United States to Seek
Parole Pursuant to the Uniting for Ukraine (U4U) Process

CBP One™ allows certain individuals to submit information to CBP in advance of their
arrival at a land Port of Entry (POE). This functionality, available under the “Submit Advance
Information” tab within the “Land” section in the “Traveler” persona, allows undocumented
individuals 18 to voluntarily submit biographic information, as well as a facial photograph, to CBP
in advance of their arrival at the POE, which will streamline processing at the POE. Typically,
once an undocumented individual arrives at a land POE for processing, CBP Officers (CBPOs)
spend significant time collecting and verifying basic biographic data about the individual during
the inspection process. One at a time, the CBPOs interview and collect information from such
individuals during secondary inspection. The CBPOs manually enter the information into the
Unified Secondary System (USEC). 19 To facilitate processing upon arrival and reduce the amount
of manual data entry into primary and secondary processing systems, CBP One™ data will be
displayed on the primary inspection screen and available for importation into secondary processing
events.
Once the individual is logged in to CBP One™, they are prompted to select “Traveler”,
then “Land”, then “Submit Advance Information”. First time users will be prompted to select their
preferred language (English or Spanish). After these steps are complete, the user must then select
“Add Individual”. CBP One™ then collects the same information that CBP would otherwise
collect during the primary and/or secondary inspection, including:
•

Facial photograph

•

First and last name

•

Date of birth

•

Nationality

An undocumented individual is an individual who does not possess a valid visa and is not traveling from a country
in which the requirement to obtain a visa is waived. Undocumented individuals may or may not possess a passport
or other acceptable document that denotes identity and citizenship when entering the United States (e.g., passport,
passport card; Enhanced Driver’s License; Trusted Traveler Program card (NEXUS, SENTRI or FAST); U.S.
Military identification card; U.S. Merchant Mariner; American Indian Card, or (when available) Enhanced Tribal
Card).
19
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR THE UNIFIED SECONDARY, DHS/CBP/PIA-067, available at https://www.dhs.gov/privacydocuments-us-customs-and-border-protection.
18

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•

Country/city of birth

•

Country of residence

•

Travel document information

•

Phone numbers

•

U.S. address

•

Foreign addresses (optional)

•

Employment history (optional)

•

Travel history (optional)

•

Emergency contact information (optional)

•

Family information

•

Marital information

•

Identity documents

•

Gender

•

Height

•

Weight

•

Eye color

For individuals arriving with co-travelers, the process discussed above will need to be
repeated, and CBP One™ will create a single submission for all co-travelers.
CBP One ™ will also collect latitude and longitude coordinates. These coordinates will
be sent to CBP to determine whether the submission is occurring within 30 miles of the U.S.Mexico border. 20 In addition, CBP One™ collects the preparer (person assisting the individual
with their submission)’s first and last name and email address.
CBP plans to eventually make the advance information submission functionality available
to all individuals, including U.S. citizens, who intend to arrive at a land POE. However, beginning
At launch, CBP One™ will not collect latitude and longitude information from individuals with an approved
advance authorization to travel to the United States to seek parole under the U4U process. CBP One™ will collect
this information from all individuals, including those with an approved advance authorization to travel to the United
States to seek parole under the U4U process, around May 23, 2022 when the advance information functionality is
rolled out to all undocumented individuals traveling to a land border.

20

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on April 25, 2022, the advance information capability will only be available to eligible Ukrainian
citizens and, as appropriate, members of their immediate family, who have an approved advance
authorization to travel to the United States to seek parole pursuant to the Uniting for Ukraine (U4U)
process. 21 Additional information related to CBP’s screening and vetting process as part of U4U
will be provided in the forthcoming Automated Targeting System (ATS) Addendum Update. 22
DHS is working with the Department of State to provide local messaging in Mexico to the
populations who would need to utilize CBP One™ to schedule their advance arrival following a
U4U travel authorization approval. The messaging will encourage individuals with an approved
advance travel authorization who intend to travel to a U.S.-Mexico land border POE to use CBP
One™ to inform CBP of their intended date and time of arrival; however, use of CBP One™ is
voluntary.
After the initial April 25th deployment, CBP will work to expand this functionality to all
undocumented individuals to allow them to submit advance information to CBP prior to their
arrival at a land POE. All individuals submitting information through CBP One ™ will be required
to be within 30 miles of the U.S.-Mexico border (as determined by the phone’s GPS at the time of
submission) and must complete liveness detection through their device’s camera 23 prior to
scheduling a presentation date at a POE.
For all individuals accessing CBP One™ on a mobile device, once the individual has
entered all biographic information as well as a facial photograph for themselves and any cotravelers, CBP One™ will display available arrival date/times based on the selected land POE.
The individual will be offered the opportunity to schedule their desired arrival land POE location,
date of arrival, and time of arrival. All individuals accessing CBP One™ on the web will be able
to submit the facial photograph as well as the other information through the web, however they
will be instructed to utilize the mobile application to select available arrival date/times. All
individuals utilizing CBP OneTM to schedule or reschedule a presentation date after their initial
submission will be required to submit a live facial photograph to access their original submission.
While CBP allows individuals to select a desired POE and date/time of arrival, this request does
See Press Release titled “President Biden to Announce Uniting for Ukraine, a New Streamlined Process to
Welcome Ukrainians Fleeing Russia’s Invasion of Ukraine”, available at
https://www.dhs.gov/news/2022/04/21/president-biden-announce-uniting-ukraine-new-streamlined-processwelcome-ukrainians.
22
See U 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) (2022), available at
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection. CBP is currently developing an update
to this PIA to discuss the collection of geolocation data to ensure an individual is within a certain range of the U.S.Mexico border.
23
CBP will not conduct liveness detection during the initial launch phase that involves only those with approved
advance authorizations to travel to the United States to seek parole under U4U.
21

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not guarantee that an individual will be processed on a given date or at a given time. After the
data is submitted, the individual is presented with a confirmation screen which displays a
confirmation number along with the selected POE and date/time, if applicable. In addition, a
confirmation email will be sent to the email address(es) provided under contact information during
the CBP One™ submission, or, in the absence of an email within CBP One™, it will be sent to
the registered email of the Login.gov account.
Prior to arrival at the POE, CBP may use the information submitted by the individual to
conduct system checks to identify individuals who may pose a risk to national security, border
security or public safety. These checks are identical to the checks conducted by CBP during the
primary or, in some cases, secondary inspection process. 24 CBP will not inform the user of the
outcome of these checks, but CBPOs will use the information during primary and secondary
inspections.
During primary inspection at the POE, the CBPO will use the Simplified Arrival system to
take a new facial photograph. 25 This facial photograph will search against multiple CBP Traveler
Verification Service (TVS) galleries including a pre-staged “Submit Advance Information”
gallery. The “Submit Advance Information” gallery consists of templates that CBP created from
the facial photograph submitted by users during the submission process. If there is a match, the
information the user submitted through CBP One™, as well as the results of the system checks,
will be displayed to the CBPO. If no match is made, CBPOs will manually enter the individual’s
confirmation number or biographic data to populate Simplified Arrival for processing in primary.
As with any individual who arrives at the POE without documentation, the CBPO will use
Simplified Arrival to create a referral to secondary for further processing, to include the
confirmation number received from CBP One™. Once referred to secondary, CBP Officers may
import the information captured through the CBP One™ application into a USEC event.
CBP will publish a standalone PIA to more fully explain CBP’s collection of information
from undocumented individuals in advance of their arrival at POE. 26
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 TECS SYSTEM: PLATFORM, DHS/CBP/PIA-021 (2016), available at
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
25
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR THE TRAVELER VERIFICATION SERVICE – APPENDIX A ON SIMPLIFIED ARRIVAL, DHS/CBP/PIA056, available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
26
CBP is currently developing a new Privacy Impact Assessment to discuss this advance information collection
titled “Collection of Advance Information from Certain Undocumented Individuals on the Land Border.” This PIA
will be available on the DHS Privacy Office website: https://www.dhs.gov/privacy-documents-us-customs-andborder-protection.
24

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1. Advance Authorization to Travel to the United States to Seek a Discretionary
Grant of Parole for Certain Undocumented Noncitizens from Select Countries
DHS has created a new Advance Travel Authorization (ATA) process 27 to vet requests for
advance authorization to travel submitted as part of the parole process for certain undocumented
noncitizens from select countries. The ATA process will provide a streamlined way for certain
noncitizens to submit personal information to USCIS and CBP to facilitate the issuance of an
advance authorization to travel to the United States to seek a discretionary grant of parole.
Persons or entities legally physically present in the United States may submit an I-134,
Declaration of Financial Support, to USCIS on behalf of an individual beneficiary potentially
eligible to receive advance travel authorization under this process. USCIS will vet the supporter,
confirm the beneficiary’s biographic information, and confirm the beneficiary’s attestation of
vaccination against measles, polio, and COVID-19. 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. 28 Travelers use their myUSCIS account to verify
their biographic information as provided on Form I-134 is accurate and to attest to all requirements.
Once the traveler has confirmed their biographic information, myUSCIS will inform the traveler
to complete their request for advance authorization to travel by downloading and using the CBP
One™ mobile application to submit biographic and biometric data.
The traveler must log into CBP One™ and 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 direct the user to “Scan Passport.” The CBP One™ mobile application
will 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
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PATROL,
PRIVACY IMPACT ASSESSMENT FOR THE ADVANCE TRAVEL AUTHORIZATION,
https://www.dhs.gov/privacy-impact-assessments.
28
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE myUSCIS Account Experience, DHS/USCIS/PIA071, available at https://www.dhs.gov/uscis-pias-and-sorns.
27

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scanned, software determines whether there is a readable eChip 29 embedded 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 date of birth, passport number, and nationality. This information
is then automatically populated into the submission of the mobile application to eliminate the need
for manual input by the traveler.
Following the collection of this information, users who have eChips will then 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 Communication 30 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.
CBP One™ collects and sends the A-Number, date of birth, and passport number to the
CBP Arrival and Departure Information System (ADIS) in order to verify that the traveler
accessing the specific functionality within CBP One™ has a USCIS-approved, U.S.-based
supporter and has verified their biographic information and has provided the DHS-required
attestations related to program eligibility criteria. 31 The Arrival and Departure Information System
directly interfaces with the USCIS Electronic Immigration System (ELIS), used to process
immigration benefits. 32 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
date of birth, nationality, sex, A-Number, passport number, and passport expiration date to the
Automated Traveler Information System (ATIS) for vetting. 33 CBP uses the passport number to
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 (VWP) 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.
30
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.
31
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.
32
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-impact-assessments; and DHS/USCIS-007
Benefits Information System, 81 FR 72069 (October 19, 2016), available at https://www.dhs.gov/system-recordsnotices-sorns.
33
ATIS 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.
29

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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. 34 If CBP cannot
confirm that the traveler has been approved by USCIS for ATA or identify a valid passport, the
traveler will not be able to complete their request for advance authorization to travel.
Once the biographic and eChip data is collected, CBP One™ prompts the user to take a
live photograph or selfie (new photograph and not the same image collected from the passport/epassport). CBP One™ instructs the user to line their face up with a circle on the screen of their
mobile device. CBP One’sTM embedded software then performs a “liveness” test to determine that
it is real person (and not a picture of a person). 35 CBP One™ allows the user to capture their image
and select “Continue” once they are satisfied it is an accurate photo. CBP One™ will reject any
images that are not correctly captured, such that only one live photograph is collected. 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 entered incorrectly. Once the user
verifies and submits their information, the data and photographs are passed to the downstream
systems described below. The CBP OneTM application will advise the user to refer to their
myUSCIS account for further information regarding their request.
Once all the required information and a new live photograph are submitted, the information
is saved in the Automated Traveler Information System and copied to CBP’s Automated Targeting
System/Unified Passenger system (ATS-UPAX) 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

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
TECS SYSTEM: PLATFORM, DHS/CBP/PIA-021 (2016), available at https://www.dhs.gov/privacy-impactassessments.
35
While the user is taking the “selfie,” the technology embedded within the mobile application relies on the devices
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.
34

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Technology System (IDENT/HART). 36,37 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.
Uses of Facial Comparison in Downstream System During ATA Process:
CBP uses facial comparison technology at various stages in the ATA process.
Although CBP One™ does not conduct any facial recognition activities, 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 mobile application 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.
Retention of Data
CBP One™ 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. 38 The selfie photograph collected through CBP
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.
37
However, a traveler’s 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. More information about this advance traveler authorization and the process at ports of entry
will be found at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
38
The aggregate data used for reporting are covered by the following records schedule: General Records Schedule
(GRS) 5.2, item 020. Intermediary Records. Temporary. Destroy upon verification of successful creation of the final
36

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One™ is passed to downstream systems and is not stored in the CBP-owned cloud. CBP will store
this photograph in the Automated Targeting System and the Automated 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. In addition, CBP One™ collects the
first and last name of the user as part of the profile creation. 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. CBP is concurrently developing a standalone Privacy Impact
Assessment to fully explain the Advance Traveler Authorization process. 39

document or file, or when no longer needed for business use, whichever is later. The reports submitted to CBP
Leadership that are generated from the aggregate data are covered by the following records schedule: DAA-05632019-0008-0003. Periodic Reports. Temporary. Cutoff at the end of the calendar year. Destroy five years after cutoff.
39
This Privacy Impact Assessment will be available on the DHS Privacy Office website:
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.

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APPENDIX B: Importers/Exporters
1.

Stakeholder Scheduling

The Stakeholder Scheduling functionality is embedded into the CBP One™ mobile
application, and provides brokers, importers, and travelers the option to voluntarily schedule
inspection appointments and assist in the management of appointments related to CBP cargo
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APPENDIX C: Non-Governmental Organizations
Updated May 7, 2021

1. Migrant Protection Protocol
In early 2019, CBP began implementing the Migrant Protection Protocol (MPP), 40 which
is a U.S. government action whereby certain foreign individuals, without proper documentation,
entering or seeking admission to the United States from Mexico are returned to Mexico to wait
outside of the United States for the duration of their immigration proceedings. In January 2021, 41
the United States ended new enrollments into MPP and, in February 2021, began the process of
permitting foreign individuals previously in MPP to be processed into the United States. In order
to enroll individuals in MPP, CBP used Unified Secondary 42 and e3 43 to collect a photograph and
biographic information from the individual. CBP stores this information in a CBP database in the
Enforcement Integrated Database (EID). 44
CBP is working with International Organizations (IO), identified by the United States
Department of State, to verify individuals enrolled in MPP whose proceedings under section 1229a
of the Immigration and Nationality Act remain ongoing to streamline their processing into the
United States. Users working for an IO will download and access CBP One™ in the same manner
as all other users of CBP One™. CBP will determine whether a user can have access to IO
functions in CBP One™ based on the information the user inputs to create a Login.gov account.
Eligible IOs will provide email domain names to CBP and CBP will open access to the
functionality within CBP One™ to users who created Login.gov accounts using that email domain.
For example, the International Organization for Migration, a designated IO, may give CBP their
email domain as @iom.int. CBP would then allow any user who created a Login.gov account using
See Policy Guidance for Implementation of the Migrant Protection Protocols (January 25, 2019), available at
https://www.dhs.gov/sites/default/files/publications/19_0129_OPA_migrant-protection-protocols-policyguidance.pdf.
41
See Executive Order 14010, Creating a Comprehensive Regional Framework To Address the Causes of Migration,
To Manage Migration Throughout North and Central America, and To Provide Safe and Orderly Processing of
Asylum Seekers at the United States Border (February 3, 2021), available at
https://www.federalregister.gov/presidential-documents/executive-orders.
42
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR UNIFIED SECONDARY, DHS/CBP/PIA-067 (2021), available at https://www.dhs.gov/privacydocuments-us-customs-and-border-protection.
43
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR THE CBP PORTAL (E3) TO ENFORCE/IDENT, DHS/CBP/PIA-012 (2012 and subsequent updates),
available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
44
EID is a U.S. Immigration and Customs Enforcement (ICE) system that stores some CBP encounter information.
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, PRIVACY
IMPACT ASSESSMENT FOR THE ENFORCEMENT INTEGRATED DATABASE, DHS/ICE/PIA-015 (2010 and subsequent
updates), available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
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a @iom.int email to view the IO functionalities.
Once a user has access to the IO functionality in CBP One™, he or she will be able to use
the application to facilitate processing of individuals that are enrolled in MPP and have an active
immigration proceeding (i.e., no final adjudication). To do this, an IO user, with the consent of
and on behalf of the individual, will take or upload an existing photograph of the individual into
CBP One™. Once the user submits the information, CBP One™ will attempt to match the image
against a pre-staged Traveler Verification Service (TVS) 45 gallery that is populated with all of the
images from the MPP EID database. If a match is made, CBP will send the biographic information
(e.g., first and last name, date of birth) associated with the EID image to the U.S. Citizenship and
Immigration Services’ Person Centric Query System (PCQS) 46 to verify that the individual still
has a pending case before an immigration judge. Individuals with a final immigration adjudication
are not eligible to continue MPP processing. Once both the EID and PCQS search are complete,
CBP sends a response back to the IO CBP One™ user which is either a green check mark, a yellow
bar, or a red “X”. Additionally, the user may receive a system error message.

A green check mark indicates that the individual, whose picture the user submitted to CBP,
is enrolled in MPP and has a pending case before an immigration judge. A yellow bar indicates
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/privacy-documents-us-customs-and-border-protection.
46
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION SERVICES, PRIVACY
IMPACT ASSESSMENT FOR THE PERSON CENTRIC QUERY SERVICE, DHS/USCIS/PIA-010 (2016 and subsequent
updates), available at https://www.dhs.gov/uscis-pias-and-sorns.
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that the individual is enrolled in MPP, but the individual’s immigration case is now closed, which
makes them ineligible for processing into the United States as an MPP enrollee or that CBP was
unable to locate an immigration case for the individual. The IO can then check the U.S. Department
of Justice’s Executive Office for Immigration Review website to determine the case status and if
the information CBP provided through CBP One™ is accurate. A red “X” means that CBP was
unable to locate MPP enrollee information in CBP’s MPP database in EID.
If they receive a red “X” the IO can submit an alien identification number (A-number) as
an alternative method of search. Additionally, the IO user can select a “decline to provide” button
when asked to provide a photograph of the individual which will allow the IO user to submit the
individual’s A-number, with consent of the individual. The A-number query will be sent to EID
and PCQS to try and locate information in those systems associated with the A-number. Like with
the photograph submission, based on the record located CBP then sends a response back to the IO
CBP One™ user with either a green check mark, yellow bar, or a red “X”. If the IO receives
another red “X”, the final option will be to collect biographic information (e.g., first and last name,
and date of birth) from the individual using CBP One™. 47 The biographic information is also
submitted to EID and PCQS to locate matching records. As with the previous queries, CBP then
sends a response back to the IO CBP One™ user with either a green check mark, a yellow bar, or
a red “X”. Along with the green check mark CBP will also provide the date the MPP enrollee was
enrolled in MPP. This will assist the IO in prioritizing MPP enrollees to present to CBP for
processing into the United States.
No information is stored locally on the user’s device. CBP does not store the photo but will
store the A-number and biographic data, if provided, in a CBP Amazon Web Services Cloud
Service (CACE) database for 365 days. This data will be retrievable by CBP employees in the
CBP Office of Information Technology in order to provide CBP leadership with anonymized
statistics related to workload and record location ability. For example, CBP employees will be able
to view number of submissions and number of submissions that required submitting the A-number
and biographic data.
CBP is publishing a separate programmatic MPP PIA that will discuss the privacy risks
and mitigations surrounding all aspects of the MPP program, including this use of CBP One™.
2. Advance Information for Certain Undocumented Individuals on the Land
Border (submitted by NGOs/IOs)

Initially, the option to input biographic information will not be available and IOs will only be able to use facial
comparison and A-number inputs. CBP plans to quickly implement the biographic input option upon roll-out of this
initiative.
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On March 20, 2020, the Department of Health and Human Services (HHS) issued an
Interim Final Rule (IFR) and Order under Section 265 and 268 of Title 42 of the U.S. Code, which
permits the Director of the Centers for Disease Control and Prevention (CDC) to “prohibit … the
introduction” into the United States of individuals when the Director believes that “there is serious
danger of the introduction of [a communicable] disease into the United States.” Section 268 of
Title 42 provides that customs officers—which includes officers of CBP’s Office of Field
Operations and Border Patrol agents—shall implement any quarantine rule or regulation issued by
the CDC, which includes Orders under Section 265. The CDC Order issued on March 20, 2020,
has been extended and amended. The most current version of the Order was issued on October 13,
2020, after HHS issued a Final Rule (FR) under Sections 265 and 268 of Title 42 of the U.S. Code.
The CDC order does not apply to U.S. citizens, lawful permanent residents, and their spouses and
children, nor does it apply to U.S. military personnel or those who arrive at a port of entry with
valid travel documents. The Order also includes an exception for anyone whom customs officers
determine should be allowed into the United States on “consideration of significant law
enforcement, officer and public safety, humanitarian, and public health interests.”
To streamline the processing at ports of entry (POE) of certain undocumented individuals
who may be determined to be excepted from the Order based on humanitarian interests, CBP will
leverage the existing CBP One™ Mobile Application (CBP) information collection functionality,
which was initially deployed in February 2021 to verify the identity and eligibility of individuals
enrolled in the Migrant Protection Protocol (MPP) program. Currently, CBP Officers (CBPO)
spend significant time collecting and verifying basic biographic data about undocumented
individuals during the inspection process. The CBPOs interview and collect information from
individuals, one at a time, during secondary inspection. The CBPOs manually enter the
information into the Unified Secondary system (USEC). 48 To facilitate processing upon arrival
and reduce the amount of manual data entry into secondary processing systems, CBP One™ data
will be available for importation into secondary processing events.
CBP is updating CBP One™ to allow IOs and now Non-Governmental Organization
(NGO), on behalf of an undocumented individual, to submit information to CBP in advance of the
individual’s arrival at a POE. The ability to submit advance information is available to the same
IOs and through the same process as outlined above in the MPP section of this appendix. CBP will
also authenticate NGOs to access the IO/NGO functionality. DHS will inform CBP of eligible
NGOs based on an NGO’s existing roles providing services to undocumented individuals. Instead
of selecting “check case status,” users will select “Submit Advance Information” in order to collect
and submit information from undocumented individuals before they arrive at a POE.
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR UNIFIED SECONDARY, DHS/CBP/PIA-067 (2020), available at https://www.dhs.gov/privacydocuments-us-customs-and-border-protection
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Undocumented individuals may voluntarily provide basic biographic information name,
date of birth, country of citizenship, contact information, addresses, nationality, employment
history, travel history, emergency contact information, familial information, marital status, nonWestern Hemisphere Travel Initiative (WHTI) compliant document information, 49 gender,
preferred language, as well as an optional picture to serve as a biometric. Once an IO/NGO has
input all of the required information and any optional data fields, they will submit it to CBP. While
no information is stored locally in the CBP One™ Mobile Application or on a user’s device, this
data is stored in a segregated backend database within the Automated Targeting System (ATS).
The information will be tagged as coming from CBP One™. Additionally, CBP will store a
templatized copy of the picture in a standalone Traveler Verification Service (TVS) gallery to be
matched against a photograph taken by a CBPO once the individual arrives at the POE using the
primary inspection system. The TVS gallery will be built off the new backend dataset ingesting
into ATS specifically for the non-MPP population. If any photos are submitted from CBP One™,
the new TVS gallery will stage those photos until they arrive at the POE. CBP discusses this
process in the TVS PIA.
Once an undocumented individual arrives at the POE, CBP will take a new photograph to
search against the new non-MPP gallery within TVS. If not found, CBPOs will manually query
ATS based on biographic data to populate simplified arrival for processing in Primary inspection.
As with any individual who arrives at the POE without documentation, the CBPO will create a
referral to Secondary inspection for further processing, which will include the confirmation
number received from CBP One™. Once an undocumented individual is referred to Secondary,
CBP will auto-populate information into the Unified Secondary system using the information
captured through CBP One™. This will limit the amount of data that needs to be collected, either
in Primary or in Secondary. In Secondary inspection, the officers will query the USEC event,
review the accuracy of the data, edit the data as necessary to ensure accuracy, and save the
information in the system. CBP is publishing an update to the Unified Secondary PIA to provide
additional transparency to the process.

WHTI is the joint DHS and Department of State (DOS) initiative to implement a key 9/11 Commission
recommendation and the statutory mandates of the Intelligence Reform and Terrorism Prevention Act of 2004
(IRTPA), which required DHS and DOS to develop and implement a plan to require all travelers, U.S. citizens and
foreign nationals alike, to present a passport or other acceptable document that denotes identity and citizenship when
entering the United States. For more information, see https://www.cbp.gov/travel/us-citizens/western-hemispheretravel-initiative.
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APPENDIX D: Transportation Security Administration (TSA)
Updated October 24, 2022

Migrant Protection Protocol Identity Verification for Domestic Flights
Transportation Security Administration’s (TSA) mission is to protect the nation’s
transportation systems to ensure freedom of movement for people and commerce. As part of its
efforts to secure aviation transportation, TSA verifies passenger identities in order to grant access
to airport sterile areas. 50 The TSA employee performing Transportation Document Checker (TDC)
functions typically manually verifies identity at the checkpoint by comparing the facial photograph
on a passenger’s identity document to the passenger’s actual face and the credential’s biographic
information to the biographic information on the passenger’s boarding pass. The TDC also checks
the boarding pass and identity credential for authenticity. Once those steps are successfully
completed, the passenger proceeds to security screening.
Individuals who are enrolled in the Migrant Processing Protocol (MPP) likely will not have
a valid travel document to present to TSA for identity verification. Therefore, once MPP enrollees
are admitted to the United States, they will generally be unable to board domestic flights to their
various destinations.
CBP has created a new user role in the CBP One™ mobile application to allow TSA
supervisors the ability to take a new photograph of the MPP enrollee and, using the Traveler
Verification Service (TVS) 51 facial comparison technology, match the individual seeking entry to
the airport sterile area with a photograph in the existing pre-staged MPP gallery. Only TSA
supervisors, using a government-issued device, will be permitted to access CBP One™ for this
purpose. These TSA supervisors must create an account with Login.gov using their TSA email
addresses to access the TSA user role in CBP One™. TSA employees will not have access to any
other CBP One™ capabilities and users that do not use the TSA email domain will not see the
TSA persona on CBP One™.
As part of their ongoing assistance to MPP enrollees, International Organizations (IO) will
provide information regarding further travel within the domestic United States, often in
coordination with domestic aid groups. The IOs are responsible for communicating to the MPP
enrollees that they must inform the TSA TDC that they lack valid travel documents but are part of
“Sterile areas” are portions of airports that provides passengers access to boarding aircraft and to which the access
generally is controlled by TSA, or by an aircraft operator or a foreign air carrier through the screening of persons
and property (49 C.F.R. § 1540.5).
51
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/privacy-documents-us-customs-and-border-protection.
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MPP. The TSA TDC will then refer the traveler to a TSA supervisor. The TSA supervisor will
take a photograph of the traveler via his or her government-issued mobile device using the CBP
One™ mobile application. CBP One™ will attempt to match the image against a pre-staged TVS
gallery that is populated with all of the images from the MPP EID 52 database. This is the same
database used for the IO CBP One™ functionality. 53
If a match is made, CBP One™ will return a green check mark with the First Name, Last
Name, Date of Birth, and Alien Number (A-Number) of the traveler. This will indicate that the
traveler is enrolled in MPP and the TSA supervisor can check the biographic information against
the traveler’s boarding pass. CBP One™ will return a red “X” if no match is found.
In the event of a “no match” or if the traveler declines to be photographed, the TSA
supervisor can input biographic information of the traveler which CBP One™ will attempt to
match against CBP’s I-94 database. 54 CBP tags MPP enrollees and qualified family members 55 in
the I-94 database and uses biographic information to search the database and locate MPP enrollees
and qualified family members. Just as in the biometric search, the biographic I-94 search will
return a green check mark or red “X” to the TSA employee through CBP One™. If the TSA
supervisor gets a red “X,” they may contact the CBP Traveler Communications Center to
determine if the traveler is an MPP enrollee or if the traveler should not be permitted to continue
through the screening process.
As with other CBP One™ uses, no information is stored locally on the device. CBP does
not store the photo but will store the A-Number and biographic data, if provided, in a CBP Amazon
Web Services Cloud Service (CACE) database for 365 days. This data will be retrievable by CBP
employees in the CBP Office of Information Technology to provide CBP leadership with
anonymized statistics related to workload and record location ability. For example, CBP
employees will be able to view number of submissions and number of submissions that required
submitting the A-Number and biographic data. TSA stores no information as part of this process.

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, PRIVACY
IMPACT ASSESSMENT FOR THE ENFORCEMENT INTEGRATED DATABASE, DHS/ICE/PIA-015 (2010 and subsequent
updates), available at https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
53
The MPP process will be more fully explained in a forthcoming CBP Migrant Protection Protocol PIA.
54
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION, PRIVACY IMPACT
ASSESSMENT FOR THE ARRIVAL AND DEPARTURE INFORMATION, DHS/CBP/PIA-024(c) (2020), available at
https://www.dhs.gov/privacy-documents-us-customs-and-border-protection.
55
Qualified family members are children or spouses of an MPP enrollee who were not enrolled in MPP because they
were not born or married at the time of enrollment. CBP makes this determination and tags the information in I-94.
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Transportation Security Administration (TSA) at Security Checkpoints
Transportation Security Administration’s (TSA) mission is to protect the nation’s
transportation systems to ensure freedom of movement for people and commerce. As part of its
efforts to secure aviation transportation, TSA is required to verify passenger identities in order to
grant access to airport sterile areas. 56 The TSA employee performing Transportation Document
Checker (TDC) functions typically manually verifies identity at the checkpoint by comparing the
facial photograph on a passenger’s identity document to the passenger’s actual face and the
credential’s biographic information to the biographic information on the passenger’s boarding
pass. The TSA TDC also checks the boarding pass and identity credential for authenticity. Once
those steps are successfully completed, the passenger proceeds to security screening.
Undocumented noncitizens may not have a valid travel document to present to TSA for
identity verification. If such individuals are not in DHS custody and permitted to travel
domestically, they will potentially be subject to lengthy verification processes prior to boarding
domestic flights to travel to various destinations. TSA employees can only use the DHS persona
in the CBP One™ application to take a photograph of certain undocumented noncitizens who lack
valid travel documents and, using CBP Traveler Verification Service facial comparison
technology, match the individual seeking entry to the airport sterile area with a photograph in CBP
holdings. The new photograph is matched against images in the Seizure and Arrest Workflow
within the Automated Targeting System (ATS). CBP creates galleries, within TVS, using the
images of certain undocumented noncitizens located in the Seizure and Arrest Workflow. The
pictures taken by TSA employees of undocumented noncitizens are matched against these galleries
for identity verification purposes only.
Only TSA employees using a government-issued device will be permitted to access CBP
One™ for this purpose. TSA employees utilizing their official TSA email domain will see a single
persona for DHS, which will allow them to utilize CBP One™ to verify the identity of the
undocumented noncitizen. TSA employees must create an account with Login.gov using their TSA
email address to access to the DHS persona in CBP One™. TSA employees will not have access
to any other CBP One™ capabilities, and employees that do not use the TSA email domain will
not see the DHS persona on CBP One™.
When a TSA TDC determines that a traveler does not have valid identification, they refer
the traveler to a supervisor to conduct the appropriate vetting and whether the traveler should be
permitted to enter the sterile area. Depending on the traveler’s interaction with the TSA supervisor
and the documents they have available, a TSA supervisor may decide to use CBP One™ to retrieve
“Sterile areas” are portions of airports that provides passengers access to boarding aircraft and to which the access
generally is controlled by TSA, or by an aircraft operator or a foreign air carrier through the screening of persons
and property (49 C.F.R. § 1540.5).

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the traveler’s identity in CBP holdings. The TSA supervisor will take a photograph of the traveler
via his or her government-issued mobile device or laptop using the CBP One™ application. CBP
One™ uses the Traveler Verification Service to templatize and match the live facial photograph
captured from the undocumented noncitizen against a facial photograph from a staged gallery that
is populated with images from the Automated Targeting System database. If a match is made, CBP
One™ will return a green check mark with the First Name, Last Name, Date of Birth, A-Number
(if available), citizenship of the traveler, and a facial photograph of the traveler (if available). The
TSA employee can then check the travelers biographic and biometric information displayed on
CBP One™ against the traveler’s boarding pass.
CBP One™ will return a red “X” if no match is found. In the event of a “no match” or if
the traveler declines to be photographed, the TSA user can search CBP One™ by the traveler’s
biographic information or A-Number. CBP One™ will attempt to match the biographic data or ANumber entered into the mobile application against the Automated Targeting System database.
The biographic or A-Number search will return either a green check mark or red “X” to the TSA
user through CBP One™. If the TSA user gets a red “X,” they can contact their National
Transportation Vetting Center to determine if the traveler should not be permitted to continue
through the screening process.
As with other CBP One™ uses, no information is stored locally on the device. CBP does
not store the photo but will store the A-Number and biographic data, if provided, in a CBP Amazon
Web Services Cloud Service (CACE) database for 365 days. This data will be retrievable by CBP
employees in the CBP Office of Information Technology to provide CBP leadership with
anonymized statistics related to workload and record location ability. For example, CBP or TSA
supervisors will be able to obtain aggregate data (e.g., number of submissions). TSA stores no
information as part of this process.