Privacy Threshold Assessment

T he Privacy Office

U.S. Department of Homeland Security

Washington, DC 20528

703-235-0780, [email protected]

www.dhs.gov/privacy

Privacy Threshold Analysis

Version date: June 10, 2010

Page 8 of 8

PRIVACY THRESHOLD ANALYSIS (PTA)

This form is used to determine whether
a Privacy Impact Assessment is required.

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under the E-Government Act of 2002 and the Homeland Security Act of 2002. 

Please complete this form and send it to your component Privacy Office. If you do not have a component Privacy Office, please send the PTA to the DHS Privacy Office:

Rebecca J. Richards

Director of Privacy Compliance

The Privacy Office

U.S. Department of Homeland Security

Washington, DC 20528

Tel: 703-235-0780

[email protected]

Upon receipt from the component Privacy Office, the DHS Privacy Office will review this form. If a PIA is required, the DHS Privacy Office will send you a copy of the Official Privacy Impact Assessment Guide and accompanying Template to complete and return.

A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy, on DHSConnect and directly from the DHS Privacy Office via email: [email protected], phone: 703-235-0780.

PRIVACY THRESHOLD ANALYSIS (PTA)

Summary Information

Date Submitted for Review: 1/19/2011

Name of Project: Refugees, Asylum and Parole System (RAPS)

System Name in TAFISMA: Refugees, Asylum and Parole System (RAPS)

Name of Component:

Name of Project Manager: Paula Ferguson

Email for Project Manager: [email protected]

Phone Number for Project Manager: (202) 272-8304

Type of Project:

Information Technology and/or System.^

A Notice of Proposed Rule Making or a Final Rule.

Form or other Information Collection.

Other: <Please describe the type of project including paper based Privacy Act system of records.>

Specific Questions

1. Describe the project and its purpose:

The Refugees, Asylum and Parole System (RAPS) is designed to support DHS in its management of asylum casework. RAPS provides the means for automated tracking of asylum cases and applications for benefits provided by Section 203 of the Nicaraguan Adjustment and Central American Relief Act (NACARA § 203) as they progress from application filing through final decision of grant, denial or referral to the U.S. Immigration Courts. A variety of clerical‐intensive functions such as interview scheduling, production of routine letters and notices, request/acknowledgment of a‐files and the compilation of reports and listings are automated through RAPS.

2. Status of Project:

This is a new development effort.

This is an existing project.

Date first developed: April 1, 1991

Date last updated: July 29, 2010

The last RAPS release was 1.7. "This Release is centered around two RAPS System Change Requests (SCRs): 8405 is the enhancement of the batch Unaccompanied Minors Report, while 8407 covers a number of changes to the RAPS HOLD function. The primary change to the HOLD function was to limit the use of the headquarters “HQ” hold code while still providing a mechanism for the field users to effectively place cases on hold as their needs dictated. "

3. From whom do you collect, process, or retain information on: (Please check all that apply)

DHS Employees.

Contractors working on behalf of DHS.

The Public.

The System does not contain any such information.

4. Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)

No.

Yes. Why does the program collect SSNs? Provide the function of the SSN and the

legal authority to do so:

The SSN information collected within the RAPS application is used to assist the DHS in enforcing the immigration laws of the United States by providing timely and accurate information about persons who are subject to those laws.

5. What information about individuals could be collected, generated or retained?

• Name/alias names

• Country Of Citizenship/Nationality

• Date of Birth/alias DOB

• A‐Number

• Present and past domestic addresses

• Gender

• Marital status

• Ethnic group

• Religion

• Immigration status information: date of entry, port of entry, status at entry

• Basis of Asylum Claim

• Social Security Number

• Country of Birth

• Work Authorization Information

• TECS (IBIS) Check Results

• Case Decision Codes

• FBI Background/Identity Check Results

• Asylum Officer Information

• US-VISIT Information

• EARM Results

• Attorney name

• Preparer name

6. If this project is a technology/system, does it relate solely to infrastructure? [For example, is the system a Local Area Network (LAN) or Wide Area Network (WAN)]?

No. Please continue to the next question.

Yes. Is there a log kept of communication traffic?

No. Please continue to the next question.

Yes. What type of data is recorded in the log? (Please choose all that apply.)

Header.

Payload Please describe the data that is logged.

<Please list the data elements in the log.>

7. Does the system connect, receive, or share Personally Identifiable Information with any other DHS systems¹?

No.

Yes.

Please list:      

United States Visitor and Immigrant Status Indicator Technology (US-VISIT)

RAPS receives encounter and watch-list information from US-VISIT.

Enforcement Alien Removal Module (EARM)

RAPS sends biographical information required to request a search to EARM.

RAPS sends biographical plus case decision and removal information (Notice to Appear) to EARM.

RAPS receives biographical information plus results of searches from EARM.

Computer-Linked Application Information Management System 4 (CLAIMS 4)

RAPS sends biographical information requested for batch TECS/IBIS (Interagency Border Inspection System) checks to CLAIMS 4.

RAPS sends case information with a request for fingerprint appointment scheduling to CLAIMS 4.

RAPS receives biographical information with TECS/IBIS (IBIS) results from CLAIMS 4.

RAPS receives case information with ASC scheduling results from CLAIMS 4.

Computer-Linked Application Information Management System 3 LAN (CLAIMS 3 LAN)

RAPS sends biographical and case information to request a Employment Authorization Document (EAD) from CLAIMS 3 LAN.

RAPS receives EAD information from CLAIMS 3 LAN.

Benefits Fingerprint Processing - Mainframe (FD-258 MF)

RAPS sends biographical information required to request fingerprint checks to FD-258 MF.

RAPS receives fingerprints check results from FD-258 MF

RAPS receives FBI Name Check results from FD-258 MF

Enterprise Service Bus (ESB)/Customer Profile Management System (CPMS)

RAPS sends FBI Name Checks Biographical information required to request name checks to ESB/CPMS.

Central Index System (CIS)

RAPS sends biographical information, updated immigration status, and A-file transfer requests to CIS.

General Counsel Electronic Management System (GEMS)

RAPS sends biographical and case information to GEMS for cases that are not approved.

National File Tracking System (NFTS)

RAPS sends report information to NFTS.

RAPS receives A-file receipt information from NFTS.

Computer-Linked Application Information Management System 3 Mainframe (CLAIMS 3 MF)

RAPS receives case information that the EAD issued from CLAIMS 3 MF.

RAPS receives case information address updates from CLAIMS 3 MF.

Enterprise Service Bus/Person Centric Query Service (ESB/PCQS)

RAPS sends Person Search inputs, which are limited to First Name, Last Name, Date of Birth, and A-Number to ESB/PCQS.

8. Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?

Unknown.

No.

Yes. Please indicate the determinations for each of the following:

Confidentiality: Low Moderate High Undefined

Integrity: Low Moderate High Undefined

Availability: Low Moderate High Undefined

PRIVACY THRESHOLD REVIEW

(To be Completed by the DHS Privacy Office)

Date reviewed by the DHS Privacy Office:      

Name of the DHS Privacy Office Reviewer: <Please enter name of reviewer.>

DESIGNATION

This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable Information.

This IS a Privacy Sensitive System

Category of System

IT System.

National Security System.

Legacy System.

HR System.

Rule.

Other:      

Determination

PTA sufficient at this time.

Privacy compliance documentation determination in progress.

PIA is not required at this time.

PIA is required.

System covered by existing PIA:      

New PIA is required.

PIA update is required.

SORN not required at this time.

SORN is required.

System covered by existing SORN:      

New SORN is required.

DHS PRIVACY OFFICE COMMENTS      

 The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and 44 of the United States Code. The following is a summary of those definitions:

•“Information Technology” means any equipment or interconnected system or subsystem of equipment, used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. See 40 U.S.C. § 11101(6).

•“Information System” means a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. § 3502(8).

Note: for purposes of this form, there is no distinction made between national security systems or technologies/systems managed by contractors. All technologies/systems should be initially reviewed for potential privacy impact.

1 PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes. Often, these systems are listed as “interconnected systems” in TAFISMA.