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 10th, 2009
Page 1 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, 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 DHSOnline 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 10th, 2009
Page 2 of 8

PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: May 7, 2010
NAME of Project: Extension of Form I-864, I-864A, I-864EZ, I-864W
Name of Component: US Citizenship and Immigration Services
Name of Project Manager: Essie Bell
Email for Project Manager: [email protected]
Phone number for Project Manager: 202-272-8035
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
Other: Extensnion of Form I-864, I-864A, I-864EZ, I-864-W



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 10th, 2009
Page 3 of 8
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Form I-864 will be used by the USCIS to determine whether the sponsor has the ability to
support the sponsored alien under section 213A of the Immigration and Nationality Act.
This form serves the purpose of standardizing the evaluations of the sponsor’s ability to
support the sponsored alien and ensures that basic information required to assess eligibility
is provided by petitioners.
Form I-864A is a contract between the sponsor and the sponsor’s household members. It is
only required if the sponsor used income of his or her household members to reach the
required 125 percent of the Federal poverty guideline. The contract holds these household
members jointly and severally liable for the support of the sponsored immigrant. The
information collection required on Form I-864A is necessary for public benefit agencies to
enforce the Affidavit of Support in the event the sponsor used income of his or her household
members to reach the required income level and the public benefit agencies are requesting
reimbursement from the sponsor.
Form I-864EZ will be used by the USCIS in exactly the same way as Form I-864, however, the
USCIS will collect less information from the sponsors as less information will be needed from
those who qualify in order to make a thorough adjudication.
Form I-864W is a form that will be used by the USCIS to determine whether the intending
immigrant meets the criteria for exemption of the section 213A requirements. This form
collects the immigrant’s basic information, such as name and address, the reason for the
exemption, and accompanying documentation in support of the immigrant’s claim that they
are not subject to section213A.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated: June 28, 2007
The forms are being extended to meet current regulatory requirements, Section 213A
requires most family-based and certain employment-based immigrants to have the
petitioning relative execute an Affidavit of Support on their behalf.

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 10th, 2009
Page 4 of 8
3.

Could the project relate in any way to an individual?1
No. Please skip ahead to the next question.
Yes. Please provide a general description, below.
Yes, these forms are used by family-based and certain employment-based immigrants to
have the petitioning relative execute an Affidavit of Support on their behalf.

4.

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.

1

Projects can relate to individuals in a number of ways. For example, a project may include a camera for
the purpose of watching a physical location. Individuals may walk past the camera and images of those
individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a
project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an
individual received chemotherapy.

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 10th, 2009
Page 5 of 8
5.

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 secuirity number is necessary to adjudicate the application.

6.

What information about individuals could be collected, generated or retained?
Name, Address, Date of birth, A-Number, E-Mail Address, Mobile Telephone
Number.

7.

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.

8.

Can the system be accessed remotely?
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
No.
Yes.

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 10th, 2009
Page 6 of 8
9.

Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes.

10.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems3?
No
Yes. Please list:

11.

Are there regular (ie. periodic, recurring, etc.) data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation4?
Yes.
No.

12.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.
Yes. Please indicate the determinations for each of the following:

2

Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

Personally Identifiable Information is information that can identify a person. This includes; name, address, phone
number, social security number, as well as health information or a physical description.
3
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.
4
This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)

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 10th, 2009
Page 7 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: May 20, 2010
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: Information Collection
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: USCIS CLAIMS 3 PIA
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/USCIS-007
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS

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 10th, 2009
Page 8 of 8
These information collections are covered by exisiting privacy documentation.
Please work with USCIS Privacy to review and revise the Privacy Act e(3) statements
on these forms.