Privacy Threshold Analysis

The 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 1 of 7

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.

The 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 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
DATE submitted for review: February 3, 2011
NAME of Project: Form G-845, Document Verification Request & Form G-845 Supplement,
Document Verification Request Supplement, Verification Information System
System Name in TAFISMA:
Name of Component: US Citizenship and Immigration Services
Name of Project Manager: Ann Marie Awori
Email for Project Manager: [email protected]
Phone number for Project Manager: 202-443-0143
TYPE of Project:
Information Technology and/or System. 
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
Other:



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.

The 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 3 of 7
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The data collected on Form G-845 and the G-845 Supplement will be used by USCIS to provide
immigration status verification responses to federal, state and local agencies.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated: 2008
Minimal updates were made to the Form in 2008.

3.

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 Social Security Number, in conjunction with other information, may be used to assist in the
verification of an individual’s citizenship or immigration status. The SAVE program has an
obligation under 8 U.S.C. 1373(c) to "respond to an inquiry by a Federal, State or local
government agency, seeking to verify or ascertain the citizenship or immigration status of any
individual within the jurisdiction of the agency for any purpose authorized by law, by providing
the requested verification or status information." To properly meet this obligation, it is
important that SAVE be able to correctly identify the individuals subject to verification to ensure
that the response that we provide relates to the correct individual. We collect SSNs on the G-845
because the SSNs are in some of the databases that we access and the SSNs assist us in properly

The 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 4 of 7
identifying individuals before we provide information on the individual to the requesting
agency.
5.

What information about individuals could be collected, generated or retained?
Name, date of birth, I-94 Number, A-Number, Student and Exchange Visitor Information
System (SEVIS) Number, Social Security Number, Certificate of Citizenship Number,
Naturalization Certificate number, unexpired foreign passport number, nationality, and/or
other immigration number on a different immigration document.

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.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems1?
No.
Yes.

Please list:

8.

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

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.

The 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 5 of 7
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

The 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 6 of 7
PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DATE reviewed by the DHS Privacy Office: March 8, 2011
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
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.

The 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 7 of 7

DHS PRIVACY OFFICE COMMENTS
The G-845 and G-845 Supplement Forms will be covered by the forthcoming
Systematic Alien Verification for Entitlements (SAVE) Program PIA and associated
SORN.