Privacy Impact Assessment

Privacy Impact Assessment
for the

USCIS Customer Relationship Interface System
(CRIS)
December 4, 2008
Contact Point
Donald Hawkins
USCIS Privacy Officer
United States Citizenship and Immigration Services
202-272-8000
Reviewing Official
Hugo Teufel III
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Abstract
The United States Citizenship and Immigration Services (USCIS) has developed the
Customer Relationship Interface System (CRIS) to provide USCIS customers with the status of
pending applications and petitions for benefits and processing time information. This PIA is
required because the CRIS database contains personally identifiable information (PII) such as Alien
Registration Number (A-Number), full name, date of birth, and address.

Overview
The USCIS Information and Customer Service Division owns and operates the Customer
Relationship Interface System (CRIS). CRIS is a web based system, accessible through the USCIS
website, that provides:
1. Customers with pending immigration benefit application case status information and
estimated processing times;
2. A web-based method for customers to report a change of address;
3. A service request tool for the National Customer Service Center (NCSC) toll-free call center
representatives to record reported issues with pending cases such as typographical errors or
non receipt of a document; and
4. A process for USCIS personnel to record the issue resolution, such as a response letter,
email or telephone conversation to the customer who reported the issue.
Users of CRIS are USCIS customers, i.e., applicants and or petitioners, their legal
representatives, and USCIS personnel.
USCIS Customers and their legal representatives consist of:
• applicants and petitioners for immigration benefits,
• employers who have filed for benefits on behalf of non-US citizen employees,
• attorneys representing applicants or petitioners,
• community based organizations (CBO) representing applicants or petitioners, and
• translators and care givers of applicants or petitioners.
USCIS personnel who use CRIS include:
• Tier 1 Customer Service Representatives (CSR): USCIS contract staff who are the first level of
customer service support for the NCSC call center. Tier 1 customer service representatives
record reported issues from USCIS customers and their legal representatives.
• Tier 2 personnel: USCIS employees providing additional expertise for customer service;
• Immigration Information Officers (IIO): USCIS employees who are trained to provide
immigration information on pending cases.
• Supervisory Immigration Information Officers (SIIO): USCIS employees with additional
expertise and provide oversight of the IIO staff within their office; and,
• USCIS headquarters personnel.
Customers can access the system via the Internet to check the applicant’s or petitioner’s
case status, estimated processing time, or to notify USCIS of a change of address. USCIS personnel
access the system via the DHS intranet.
Customer PII collected by CRIS includes:

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Customer biographic information, such as name, current and previous address, date of birth,
country of birth, country of citizenship, Alien Number (A-Number), name of school or
employer the customer attends or works for, port of entry into the United States, date of entry,
and length of stay;
Receipt number, which is a number assigned by USCIS upon receipt of each application
according to when and where the application was received;
Contact information, such as home and work phone numbers and email addresses; and
System access information, such as login identification (ID), password, and security questions
and answers.

CRIS System Components
Users may interface with CRIS in two ways: via the Internet at www.USCIS.gov, or via the
phone by calling the NCSC at (800) 375-5283 or 1-800-767-1833 (TTY). There are four
components to CRIS: Case Status Service Online (CSSO) and Change of Address Online (CoA),
which the customer interfaces with directly via the Internet, and Customer Service Gateway and
Service Request Management Tool (SRMT), which are only accessible to USCIS personnel who
interface with the customer primarily over the phone.
Customer Interfaces
Case Status Service Online (CSSO)
CSSO provides status updates on pending immigration benefits applications and petitions
to USCIS customers and their representatives. Individual customers and their representatives can
access CSSO via the Internet and enter their receipt number which they received when they filed
the application or petition. The receipt number is a unique confirmation number that USCIS
provides the customer upon receipt of an application or petition for immigration benefits. After the
user submits the receipt number, CSSO will display the current status of the case. In addition, users
may create an online portfolio to receive updates of the status of multiple cases by providing user
information and the receipt number for each case status to be tracked. They use these portfolios to
monitor case status information and receive updates via email. USCIS personnel may access the
system, usually to verify the pending status and the processing timeframes prior to creating a
service request initiated by the user.
Change of Address Online (CoA)
CoA allows a customer to readily meet the federally mandated requirement that non-US
citizens notify USCIS of any change of address. Customers may electronically submit their Form
AR-11, Alien's Change of Address Card, and print their completed Form AR-11 for their records. If
they have pending applications or petitions with USCIS, the customer may additionally opt for CoA
Online to create a service request for USCIS to update those applications or petitions with their new
address.
USCIS Personnel Interfaces
Customer Service Gateway
The CRIS Customer Service Gateway displays the appropriate scripts for answering a
customer’s question on the customer service representative’s screen. These scripts are tailored for
Tier 1 customer service representatives to explain laws, regulations, and USCIS forms information
in response to customer questions. No PII is collected in this component of CRIS.

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Service Request Management Tool (SRMT)
SRMT provides USCIS customer service staff the ability to document a customer’s issue
with a pending case in a Service Request (SRs). SRs are then accessible by SIIOs and IIOs at USCIS
offices and service centers where the customer's application or petition is pending a decision and
allows the SIIOs and IIOs to document what was done to address the issue and then allows for the
creation of a response letter or email to inform the customer of how the issue they reported to
USCIS was resolved. Typical issues include typographical errors, the non-receipt of information,
change of beneficiary information, and cases not processed within USCIS stated processing times.
SRMT provides USCIS the ability to send the service request to the appropriate USCIS location for
resolution and then to record the resolution of the issue by response letter, email or telephone
correspondence to the customer who reported the issue.

Section 1.0 Characterization of the Information
1.1

What information is collected, used, disseminated, or
maintained in the system?

CRIS collects the minimum amount of information necessary to provide customer service.
CSSO Data Elements
Individual customers and their representatives can access CSSO at any time to check the
status of one application, or may opt to create an account to check the status of multiple
applications at once and/or receive notification when status changes.
To do a one-time check of the status of one application, CSSO only requires that the
individual input the application receipt number on the USCIS website and click the “go” button to
retrieve the case status. The receipt number is a number assigned by USCIS upon receipt of each
application and mailed to the applicant to confirm that the application was received. The number is
comprised of: a numeric code for which USCIS Service Center received the application; a case
number assigned chronologically by the application’s appropriate case management system; and,
except in applications for naturalization, on which fiscal year and day the application was received.
If the individual opts to create an account to track multiple applications and receive email
updates when status changes, CSSO collects the minimum amount of PII necessary to allow the
individual to track a portfolio of receipt numbers. All case status information provided online is
non-attributable information and therefore, no sensitive information is required to be collected.
The following information is collected from the USCIS customer for CSSO and most of the fields
are optional. The fields marked with an asterisk (*) below are mandatory:
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Salutation
First Name
Last Name
City
State
Country
Postal Code

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Email address*
User ID*
Password*
Security Question*
Security Answer*
Application/Petition Receipt Number*

CSSO receives case status updates from the USCIS Computer Linked Account Information
System (CLAIMS) 3 (which contains case status information on all benefits except refugees, asylees,
and naturalization petitions) and CLAIMS 4 (which contains case status information on

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naturalization petitions) systems. 1 Information is sent electronically on a daily basis to the CRIS
database with a case Receipt Number and the new updated status of that case in the form of a case
status code. CSSO uses that code to return customer a detailed explanation of the case status for
each receipt number provided. A case status code is an abbreviation of the specific status of an
application, and does not contain PII. CSSO uses the case status code to display an explanation of
the case’s status, such as:
Your case is currently undergoing a required review by an immigration officer. We will notify you by mail as soon as the
review is completed and a decision is made. If you move while this case is pending, please use our Change of Address online
tool or call 1-800-375-5283 to update your address. You can use our processing dates to estimate when your case may be
processed by following the link below. You can also receive automatic e-mail updates as we process your case by registering in
the link below.
Your permanent resident card is now under production and should be mailed to you within 30 days. If you move while your
card is being created, please contact customer service at 1-800-375-5283 to update your mailing address. You can also
receive automatic e-mail updates as we process your case by registering in the link below.
On , we determined that this was not properly filed because the application or
petition was not signed. Therefore, we have rejected your case and returned it to you with all supporting materials. Please
follow the instructions on the notice to sign the application or petition and submit the case.
CoA Data Elements
When a non-US citizen moves he or she must notify USCIS of their new address. The
information collected by Change of Address Online is the following:

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First Name
Middle Name
Last Name
Status in the United States
Country of Citizenship
Date of Birth
Alien Number
Country of Birth
Phone number
Alternate phone #
Email address
New Street Address (city, state, zip code)
Length of Stay if Temporary Address
Last Street Address (city, state, zip code)

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Employer/School name
Employer/School Street address (city,
state, zip code)
Length of Stay in the United States
Port of Entry into the United States
Date of Entry into the United States
Representative First Name
Representative Last Name
Representative Firm Name
Beneficiary Type
Beneficiary First Name
Beneficiary last name
Beneficiary Date of Birth
Beneficiary Country of Birth

Customer Service Gateway Data Elements
USCIS does not collect personally identifiable information from individuals via the
Customer Service Gateway. The Customer Service Gateway consists of scripts for USCIS customer
service staff to read in response to customers who call the customer service center according to the
information the customer is seeking. If the customer has a question or issue that requires the
collection of the customer’s information, that information is collected in the SRMT component of
CRIS.
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PIAs for these systems are available at www.dhs.gov/privacy.

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SRMT Data Elements

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When a customer calls the NCSC call center and a USCIS customer service representative
determines that they have a legitimate issue which needs to be addressed on a pending application
or petition, the USCIS customer service representative collects information from the customer. The
specific information collected is determined by the type of application or petition filed along with
the type of issue the customer is reporting. The complete list of PII that may be collected and
stored within SRMT is as follows:
• Receipt Number
Filing Date
• Status in the United States
Form Type
• Date of Birth
Service Request Type
• Beneficiary Type
Caller Type
• Beneficiary Date of Birth
Applicant First Name
• Country of Birth
Applicant Last Name
• Firm or School Name
Beneficiary First Name
• Length of Stay in the United States
Beneficiary Last Name
• Port of Entry into the United States
Representative Firm Name
• Customer Comment
Street Address (city, state, zip code)
• User ID
Email address
• Password
Phone number
• Security Question
Alternate Phone number
• Security Answer
Alien Number
USCIS employees use SRMT to process service requests, record their actions taken for each
issue reported and they can generate correspondence in the form of letters and emails addressed to
the individual(s) who contacted USCIS notifying them of the actions taken on their pending case.

1.2

What are the sources of the information in the system?

Immigration case status is collected from USCIS’s Computer Linked Application
Information Management System (CLAIMS) 3 and CLAIMS 4 and fed into the CRIS system.
CLAIMS 3 is the case management system for all applications except naturalization, asylum, and
refugee status, and CLAIMS 4 processes naturalization applications. This information is used in
CSSO and SRMT. The customer provides the remainder of the information for SRMT, CSSO, and
CoA. USCIS Content Management Office (CMO) provides the scripts used in the Gateway.

1.3

Why is the information being collected, used,
disseminated, or maintained?

The CSSO information is maintained and disseminated to enable USCIS customers to create
online accounts which enable them to quickly access their case status information and receive email
updates. The CoA information is collected as required by Section 265 of the INA (8 U.S.C. 1305)
which requires all aliens to report a change of address to USCIS within ten days of the move. The

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SRMT data that is collected enables USCIS to document and record the resolution to customer
reported issues with their pending applications or petitions.

1.4

How is the information collected?

The CLAIMS 3/CLAIMS 4 data is electronically fed to CRIS as applications are processed by
USCIS. The status information that CRIS receives is only a status code for a particular receipt
number which CSSO uses to display the current status of the application or petition (e.g. received,
reviewing, relocated, card mailed, fee received, denied, approved, etc.) Customers provide
information over the Internet within CSSO to create an online account and track status information
by receipt number. Customers can also update their addresses over the Internet by providing
change of address information, old residence and mailing address, new residence and mailing
address to CoA Online.
USCIS customer service representatives access SRMT to enter information provided by the
customer over the phone, which creates the SR. USCIS personnel who process SRs then access
SRMT to see reported issues and to record the letter, email, fax or telephone correspondence they
have with the customer to respond to the issue reported. Depending on the complexity of the SR,
USCIS personnel may access any of the internal case status tracking systems at their disposal
(usually CLAIMS 3 or CLAIMS 4) to resolve the issue.

1.5

How will the information be checked for accuracy?

The information collected by CRIS is viewed by USCIS personnel and is used to lookup the
customer’s records within the official case management systems. Self-verification by the customer
entering account setup information for CSSO on the Internet and visual inspection of SRMT
collected information by USCIS personnel is used to verify the accuracy of the data. The status
codes within CLAIMS 3/CLAIMS 4 are provided to CSSO by an electronic data feed. The data feeds
to CSSO are automatic without human intervention to prevent error and to ensure the accurate
mapping of case status updates to receipt numbers within CSSO. For the Customer Service
Gateway, USCIS personnel provide the scripts and no PII is involved.

1.6

What specific legal authorities, arrangements, and/or
agreements defined the collection of information?

8 U.S.C. 1101 et seq. of the United States Immigration and Nationality Act, provides
authority for development and maintenance of CRIS.

1.7

Privacy Impact Analysis: Given the amount and type of
data being collected, discuss the privacy risks identified
and how they were mitigated.

Privacy Risk: Unauthorized access to a customer’s information
Mitigation: CRIS does not provide any personally identifiable information to requestors
online. The only information that is provided is the application status, and this information is
generic and cannot be used to deduce an individual’s identity. Additionally, a case status response
requires that an individual submit a valid receipt number. The receipt number does not indicate or

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correspond to any personally identifiable information about the customer, but rather the location
and date the application was received.
Privacy Risk: Changes or updates to application data via requests from unauthorized
individuals.
Mitigation: CRIS does not validate the entries made by the customers and data collected by
the customer service representatives. This risk is mitigated by CRIS not providing any automated
updates to USCIS case management systems. The PII which is collected by CRIS is manually
reviewed by USCIS personnel prior to any updates being made within the CLAIMS 3/CLAIMS 4
systems. USCIS personnel independently verify that an update or change is necessary for the
application information, such as identifying a typographical error or correcting a transposed first
name and last name. If a change is made, a notice is sent to the mailing address on file for that
application to ensure that the notification goes to the original source of the application.
Privacy Risk: Collection of more information than necessary to fulfill system function.
Mitigation: Only the minimum amount of PII necessary is collected by each CRIS module
for the particular task requested and only enough information to uniquely identify the pending
application or petition.

Section 2.0 Uses of the Information
2.1

Describe all the uses of information.

CRIS only collects information to assist USCIS in matching accounts within CSSO and
service requests within SRMT to the correct application or petition. The PII collected is used by
USCIS personnel for researching reported issues and for sending current case status information on
pending applications or petitions.
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CSSO: PII elements consisting of the email address and application/petition receipt
number are required to obtain current case status information and send that information to
the customer. User ID, password, security question and answer are used to setup an online
secure account and the country and zip code are used to gather demographics of user
accounts

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SRMT: PII elements noted in Section 1.1 allow the USCIS representative to collect the
necessary and minimum amount of information required for USCIS personnel who will
research the reported issue to validate that the person calling with the issue has pending
application/petition and that the reported issue is valid, such as a typographical error
reported on a pending application, or a change in beneficiary on a petition. The address
information collected within the service request is used to form a response letter to be
mailed to the customer and their representative explaining how USCIS addressed the
service request.

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CoA: PII elements collected are those necessary to submit an electronic Form AR-11
(Change of Address form) rather than mailing a paper-based AR-11 for non-US citizens to
notify USCIS of any address change as required by law.

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2.2

What types of tools are used to analyze data and what type
of data may be produced?

The CRIS components do not conduct any electronic analysis of PII. All data is collected
for reference purposes only by USCIS personnel and CRIS does not update any other
application/petition processing systems used for the adjudication of pending applications or
petitions.

2.3

If the system uses commercial or publicly available data
please explain why and how it is used.
CRIS does not use commercial or publicly available data.

2.4

Privacy Impact Analysis: Describe any types of controls
that may be in place to ensure that information is handled
in accordance with the above described uses.

Privacy Risk: Information may be outdated, inaccurate, irrelevant, or incomplete.
Mitigation: Customer provides PII directly to CRIS either online or to a USCIS customer
service representative, therefore self-verifying the timeliness, accuracy and completeness of the
information. Additionally, the function of SRMT allows customers to file a Service Request in order
to update or correct application information, and those corrections are made by trained USCIS
personnel who verify the need for a correction or change, independent of the service request, such
as correcting a typographical error or a transposed first and last name.
Privacy Risk: Information may be compromised or accessed by unauthorized individuals.
Mitigation: The CSSO customer created accounts are protected by use of secure Internet
protocols, strong password and login authentication, and database encryption algorithms. USCIS
personnel trained in the appropriate use of PII manually collect the PII for SRMT from the customer
who has initiated the contact to request a service request. Further, the data is stored within a secure
Federal data center and protected by data security policies controlling the operations of DHS
databases.

Section 3.0 Retention
3.1

How long is information retained?

CSSO: Case status data will be maintained for one year within CRIS after a final decision,
such as Approval or Denial of the application or petition, has been made. Case Status information
is then transferred to tape for five years. After that time, data will be deleted/destroyed. Case status
data in CRIS comes from the CLAIMS 3 and CLAIMS 4 systems, where that information is separately
maintained electronically and destroyed 15 years after the last action pertaining to the application
according to the Benefits Information System Privacy Act system of records notice, DHS-USCIS007, September 29, 2008 73 FR 56596.
CoA: The CoA information is transferred daily to the USCIS AR-11 electronic storage and
retrieval system via an automatic data transfer and stored within the AR-11 system. Information

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located in the AR-11 system is maintained and disposed of in accordance with its NARA Data
Retention Schedule, which states that the last Form AR-11 received from a registrant is destroyed 5
years after the date of receipt unless destroyed upon naturalization, departure, or the registrant’s
death. The CRIS CoA data collected is handled as a sub-system to SRMT and is retained according
to the SRMT data retention schedule.
SRMT: SRMT data is maintained within CRIS for access by USCIS personnel for 90-days
after the Service Request has been closed. After that time, the data is moved into Archive Tables,
which are inaccessible by users, and are then moved to tape and taken out of the system after one
year and transferred to tape for 5 years. After that time, data is destroyed. A record of the Service
Request and action taken to close the request may also be printed and filed into the applicant’s AFile, where it is stored for retained for 75 years from the date the file is retired to the Federal
Records Center or date of last action (whichever is earlier) and then destroyed.

3.2

Has the retention schedule been approved by the
component records officer and the National Archives and
Records Administration (NARA)?

USCIS has approved the retention schedule and has proposed it to the National Archives
and Records Administration (NARA).

3.3

Privacy Impact Analysis: Please discuss the risks
associated with the length of time data is retained and how
those risks are mitigated.

Privacy Risk: Data collected in CRIS may be maintained for longer than necessary to fulfill
the operations of the system.
Mitigation: CRIS determined that the minimum period necessary to hold the data is one
year on-line and five years archived in backup tapes because data within the CRIS system is of the
same nature as written correspondence and should therefore be retained according to the same
policies as written correspondence received and generated by USCIS for auditing and accountability
purposes.
Privacy Risk: Data retained by CRIS may be accessed by unauthorized users.
Mitigation: The CRIS system and its database undergo an annual security assessment and
every three years a re-certification for accreditation. The CRIS security controls and annual security
reviews provide an assessment of the risks to loss of CRIS data for the organization. CRIS security
controls are continually monitored to ensure that all risks are mitigated by following proper
security measures. Roles based access to information is controlled and monitored within CRIS so
that limited information is provided on a restricted basis and data access is audited to ensure proper
access restrictions are in place.
Privacy Risk: PII may be accessible in CRIS for longer than is necessary.
Mitigation: Internet access to information is limited to non-personally identifiable case
status information. Intranet access by USCIS personnel to customer data is only available while the
service request is being processed and up to 90-days after the service request is closed. After that
time, the customer information in the service request is moved to archive tables which are
inaccessible to users. This further limits the amount of accessible information within CRIS to
authorized users until such time as the data can be taken offline to tape storage and subsequently
destroyed.

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Section 4.0 Internal Sharing and Disclosure
4.1

With which internal organization(s) is the information
shared, what information is shared and for what purpose?

The only system that CRIS regularly sends information to is the AR-11 Change of Address
system within USCIS. CRIS provides all data from the electronic AR-11 form daily via a daily
electronic batch data feed to the USCIS AR-11 CoA system. Service Requests collected via SRMT
are shared with USCIS personnel who review the requests and make necessary changes to the
appropriate case management system, such as CLAIMS 3 or CLAIMS 4. Depending on local office or
service center policies, USCIS staff may also file a copy of the action in the applicant’s A-File.
DHS has other systems, covered by separate PIAs available on www.dhs.gov/privacy,
which may use CRIS data to conduct analysis, such as the USCIS Fraud Detection and National
Security (FDNS) system and the Immigration and Customs Enforcement (ICE) Pattern Analysis and
Information Collection (ICEPIC). Additionally, data collected in CRIS may be shared with DHS
Information and Analysis (I&A) analysts for national security purposes in accordance with DHS’s
information sharing responsibilities.

4.2

How is the information transmitted or disclosed?

The AR-11 change of address data is electronically transferred over the secure USCIS
intranet to the USCIS AR-11 system. Information within SRMT is accessed electronically by SIIOs
and IIOs, who manually make corrections to data within the CLAIMS 3 or CLAIMS 4 systems.
Information shared for fraud detection or national security purposes is provided by referrals from
USCIS personnel and transferred directly between appropriate analysts.

4.3

Privacy Impact Analysis: Considering the extent of internal
information sharing, discuss the privacy risks associated
with the sharing and how they were mitigated.

Privacy Risk: Information shared outside of CRIS may be used for purposes beyond the
reason for the initial collection.
Mitigation: All information collected via CRIS (in CoA and SRMT) is shared with the
internal USCIS system directly associated with the corresponding application information, such as
CLAIMS 3, CLAIMS 4, AR-11, and the A-File. This sharing is done to comply with the customer
request that application information be updated. Additional data sharing is associated with fraud
detection and national security purposes, which supports the integrity of the immigration benefit
system process and USCIS’s information sharing function as a component of DHS.
Privacy Risk: Unauthorized access to information shared outside the system.
Mitigation: Change of Address information is the only CRIS-related data that is shared
internally on a regular basis. The data comes directly from the customer and is securely submitted
electronically (as noted in Sections 8 & 9 of this document) to CRIS and then to the AR-11 system,
thus greatly reducing the risks associated with unauthorized access or data entry errors when
transferring data. Information collected within SRMT and CSSO is accessible by online secure
accounts by internal USCIS personnel only. The information remains within USCIS and only USCIS
personnel have accounts to access CRIS data. Information collected is not shared with other systems

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electronically. Information within SRMT is viewed by SIIOs and IIOs to manually make corrections
to data within the CLAIMS 3/CLAIMS 4 systems.

Section 5.0 External Sharing and Disclosure
The following questions are intended to define the content, scope, and authority for information
sharing external to DHS which includes Federal, state and local government, and the private sector.

5.1

With which external organization(s) is the information
shared, what information is shared, and for what purpose?

CRIS does not share any PII with organizations outside of DHS. Information submitted to CRIS
to update the applicant’s file is passed to another USCIS system such as AR-11, CLAIMS 3, CLAIMS
4, or the A-File, and information may be shared from those systems. The information CRIS
provides to customers is limited to case status information, which is not personally identifiable.
Case status information is shared online to anyone who inputs a valid receipt number in CSSO.

5.2

Is the sharing of personally identifiable information outside
the Department compatible with the original collection? If
so, is it covered by an appropriate routine use in a SORN?
If so, please describe. If not, please describe under what
legal mechanism the program or system is allowed to
share the personally identifiable information outside of
DHS.

CRIS does not share any PII with organizations outside of DHS. USCIS does share information
from other systems outside of DHS, and some of the information in those systems may originate
from data collected in CRIS. That sharing is compatible with the collection of the information and
covered by the routine uses in the following system of records notices: Benefits Information
System DHS-USCIS-007, September 29, 2008 73 FR 56596, Fraud Detection and National
Security Data System (FDNS DS) DHS-USCIS-006, August 18, 2008, 73 FR 48231, and/or
Alien File (A-File) and Central Index System (CIS) DHS-USCIS-001, January 16, 2007, 72 FR
1755.
Case status information, which is provided in generic, non-personally identifiable format, is
shared as part of the purpose of the system, to determine the status of pending applications and/or
petitions for benefits.

5.3

How is the information shared outside the Department and
what security measures safeguard its transmission?

CRIS displays case status information online or sends it via email to addresses associated with
CSSO accounts to any individual who is able to provide a valid receipt number. CRIS maintains an
audit trail of all user successful log-on and log-off activity and password change actions.
Additionally, automated case status information sent to a customer via email has an audit trail
available for review.

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CRIS does not share personally identifiable information directly outside the Department, but
does share with systems that share outside of DHS as described by the system of records notices
identified in 5.2, above.

5.4

Privacy Impact Analysis: Given the external sharing,
explain the privacy risks identified and describe how they
were mitigated.

Privacy Risk: Unauthorized individuals may use CSSO to obtain information that does not
pertain to them.
Mitigation: CRIS does not provide any personally identifiable information to requestors
online because it does not authenticate that the requestor is actually the customer or his
representative The only information that is provided is the application status, and this information
is generic and cannot be used to deduce an individual’s identity. Additionally, a case status
response requires that an individual submit a valid receipt number. The receipt number does not
indicate or correspond to any personally identifiable information about the customer, but rather
the location and date the application was received. USCIS provides customers their application
receipt numbers on receipt notices mailed to the address provided on the application, and cannot
be obtained online or via phone to prevent unauthorized access.
Additionally, CRIS does not provide any automated updates to USCIS case management
systems. The PII which is collected by CRIS is manually reviewed by USCIS personnel prior to any
updates being made within the CLAIMS 3/CLAIMS 4 systems. USCIS personnel independently
verify that an update or change is necessary for the application information, such as identifying a
typographical error or correcting a transposed first name and last name. If a change is made, a
notice is sent to the mailing address on file for that application to ensure that the notification goes
to the original source of the application.

Section 6.0 Notice
6.1

Was notice provided to the individual prior to collection of
information?

Collection of data within CRIS is covered by the Benefits Information System system of
records notice, DHS-USCIS-007, September 29, 2008 73 FR 56596. Prior to establishing an
online account or entering change of address information online, customers are presented with a
Privacy Act Statement as required by Section (e)(3) of the Privacy Act..
The Privacy Act Statement details the authority to collect the information requested and
uses to which USCIS will put information the customer provides on immigration forms and in
support of an application. The forms also contain a provision by which a customer authorizes
USCIS to release any information received from the customer as needed to determine eligibility for
benefits.
As Case Status Online and Change of Address Online are the only systems that are directly
accessible to the public, both of these systems prominently display a Privacy Statement required by

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Section (e)(3) of the Privacy Act and also provide a link to the DHS web-privacy policy. The
Privacy Statements for Case Status Online and Change of Address online are available in Appendix A
of this PIA.
Before a Tier 1 customer service representative collects information from the public and
enters that information into SRMT, the customer is asked a series of questions and notified that
information will be collected to assist with the recording of the Service Request to assist in a timely
response and follow-up by USCIS

6.2

Do individuals have the opportunity and/or right to decline
to provide information?

Case Status Online does not require the input of PII unless the individual wants to create a
Case Status account. Because this service is optional, individuals have the opportunity to decline to
provide information. If they choose not to provide the information, they will not have the ability
to create an account and receive automatic case status updates.
When Change of Address information is provided online, the customer has the right to
decline to provide PII; however, the customer is informed at the point of collection that a change
of address cannot be completed without providing this information. This is also true for updating
the address for an application or petition. According to 8 U.S.C. 1305, all aliens are required by
law to provide a change of address within ten days of the date of that change. Failure to provide
the change of address may result in penalties, including fines not to exceed $200 and/or
imprisonment of no more than 30 days. 8 U.S.C. 1306 (b).
SRMT also collects PII in order to complete a Service Request. It remains within the rights
of the customer or their representative to decline to provide the required information for the
Service Request; however, this will result in the inability to complete the request.

6.3

Do individuals have the right to consent to particular uses
of the information, and if so, how does the individual
exercise the right?

The customer must register and use a User ID and Password for authentication before the
use of CSSO or CoA online. Customers must accept the terms and conditions for how information
will be collected and used as well as how the unauthorized use of the system is prohibited. If they
do not agree to these terms, they may still obtain case status information online, but they will not
be able to register for automatic emails on case status updates.. In addition, the privacy policy link
describes all potential uses for the collected information.

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6.4

Privacy Impact Analysis: Describe how notice is provided
to individuals, and how the risks associated with
individuals being unaware of the collection are mitigated.

Privacy Risk: Individuals may be unaware that their information is being collected and
used by USCIS.
Mitigation: Notice is provided when customers speak with USCIS personnel and via the
Internet, as outlined above. Individuals are not unaware that information is being collected as they
are prompted with online forms for data entry and if they are calling USCIS with an issue, the
customer service representative informs the customer that they require the collection of
information in order to properly record the customer’s service request.

Section 7.0 Access, Redress and Correction
7.1

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

Users who create online CSSO accounts must authenticate via a secure login using the
username, password, and security questions used to create the account. Once authenticated,
individuals may access the information they used to create their profiles, such as name and location
information as well as their password reset and security question and answer on file. The
customers also have access to their case status portfolio of receipt numbers to add and delete cases
for which they desire updated case status information.
Change of Address information collected by the customer online is not accessible by the
customer after the submission of the information to USCIS. No further edits or review of the data
are available once the information has been submitted. If the information is incorrect, the
customer must re-submit with corrected information.
For SRMT, data which is collected from the customer by the customer service
representative cannot be accessed by the customer. Once collected, the customer must wait for
USCIS to respond to their service request. If 30 days goes by and the customer is not contacted
customer service and without a response, the customer may contact customer service again with
the same issue to create a secondary service request for the same issue.
If a FOIA or Privacy Act (PA) concern arises, CRIS customers can file a FOIA request to gain
access to their USCIS records. USCIS has final discretion on the application of statutorily based
withholding or releasing the requested information. If an individual would like to file a FOIA/PA
request to view their USCIS record, the request can be mailed to the following address:
U.S. Citizenship and Immigration Services
National Records Center
FOIA/PA Office
P.O. Box 648010
Lee’s Summit, MO 64064-8010

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7.2

What are the procedures for correcting inaccurate or
erroneous information?

Customers can make changes in their CSSO account by logging in and making the
correction to information they provided. If Case Status information appears to be inaccurate, the
customer can contact USCIS customer service. For Change of Address, if the customer has made a
mistake with their address and they have submitted their information to USCIS, they may repeat
the original process and submit a correct address or they may contact USCIS customer service at 1800-375-5283 and speak with a customer service representative.

7.3

How are individuals notified of the procedures for
correcting their information?

The USCIS website contains links for the CSSO and CoA components and lists the toll free
phone number for customer assistance.

7.4

If no formal redress is provided, what alternatives are
available to the individual?

If the USCIS customer service representative is unable to address the customer’s issue, a
service request is taken with SRMT and forwarded to the appropriate office or service center with
USCIS or the phone call is transferred to a Tier2 Immigration Information Officer to provide
further information to the customer.

7.5

Privacy Impact Analysis: Please discuss the privacy risks
associated with the redress available to individuals and
how those risks are mitigated.

Privacy Risk: Individuals may not be able to access or correct their information in CRIS.
Mitigation: Because redress is inherently the same process as the original submission of
information, CRIS allows for access and redress. Users may contact USCIS via the toll free phone
number and report issues for as long as their cases are pending with USCIS. They may also access
case status information online as long as they have valid receipt numbers for their pending cases.
Privacy is protected on updates and new reported issues as with the original submission of data.

Section 8.0 Technical Access and Security
The following questions are intended to describe technical safeguards and security
measures.

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8.1

What procedures are in place to determine which users
may access the system and are they documented?

CSSO users are identified online as those customers and their legal representatives who
have a pending application or petition with USCIS. This information is provided on the Internet on
the CSSO website to clearly identify who may establish an account online for CSSO status updates.
Any person interested in receiving case status information for a pending USCIS application or
petition may create an online account.
SRMT users are identified and authorized by the USCIS Information and Customer Service
Division, Service Center Operations, Field Operations and Asylum offices. Access to SRMT is
restricted by USCIS management and limited to USCIS personnel and approved contractor staff:
•

•
•
•
•

Tier 1 customer service representatives – USCIS contractors, the first level of customer service
support on the toll free customer service number, who record reported issues from customers
and their representatives
Tier 2 personnel – USCIS employees providing additional expertise for customer service
Immigration Information Officers (IIO) – USCIS employees trained to provide immigration
information on pending cases.
Supervisory Immigration Information Officers (SIIO) – USCIS employees with additional
expertise and functions, and providing oversight of the IIO.
USCIS Headquarters personnel

8.2

Will Department contractors have access to the system?

Yes, contractors have access to CRIS. USCIS establishes personnel security requirements for
contractors (additional claims processing staff and Tier1 customer service organizations) . USCIS
requires an approved Interconnectivity Security Agreement (ISA) be established prior to contractor
staff being granted access to the CRIS Intranet modules. All contractor staff are required to undergo
a security clearance prior to being granted an account online with SRMT. Once granted a
clearance, contractor staff are further restricted within CRIS by role-based security to restrict data
access for collection only.

8.3

Describe what privacy training is provided to users either
generally or specifically relevant to the program or
system?

The USCIS personnel are required to receive annual security awareness training. The
security awareness training covers how to handle personally identifiable information. Refresher
training is required every year.

8.4

Has Certification & Accreditation been completed for the
system or systems supporting the program?
CRIS received ATO on July 28, 2008 which is valid until July 28, 2011.

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8.5

What auditing measures and technical safeguards are in
place to prevent misuse of data?

CRIS maintains an audit trail of all user successful log-on and log-off activity and password
change actions. Additionally, automated case status information sent to a customer via email has
an audit trail available for review. For SRMT, all activity performed on a customer’s Service
Request, such as assigning the request to be fulfilled, relocating it to another office, placing the
request into a pending status for further research, etc., is logged, noting who performed the action
and when it was performed. For further traceability of actions performed on CRIS data, all updates
to CRIS tables contain audit information with who made the edit or update and when each update
occurred. The auditable information within CRIS cannot be deleted by any of the roles within the
system and are only accessible by system administration personnel. Further safeguards to CRIS
modules include 20-minute inactivity user session timeouts and the restrictions to have only one
active session per user.

8.6

Privacy Impact Analysis: Given the sensitivity and scope of
the information collected, as well as any information
sharing conducted on the system, what privacy risks were
identified and how do the security controls mitigate them?

Privacy Risk: Unauthorized users may gain access to data stored in CRIS.
Mitigation: Access and security controls have been established to mitigate privacy risks
associated with authorized and unauthorized users; namely, misuse and inappropriate
dissemination of data. CRIS utilizes a role-based approach to user access. Each role has specific
rights assigned to it. Audit trails will be kept in order to track and identify any unauthorized use of
system information. Data encryption using Internet Secure Socket Layer data encryption is
employed on all CRIS applications and user passwords are stored in the database using a 3-DES
encryption algorithm. These multi-layer encryption technologies are employed to ensure that only
those authorized to view the data may do so and that the data has not been compromised while in
transit. Further, CRIS complies with DHS security guidelines, which provide restrictions on the
hardware and operating systems which the CRIS system can be hosted and where they can be
located. All of these security restrictions control the safeguarding of CRIS data against unauthorized
access to customer data and prevent undisclosed information dissemination.

Section 9.0 Technology
9.1

What type of project is the program or system?
CRIS is an operational customer service system.

9.2

What stage of development is the system in and what
project development lifecycle was used?
CRIS is currently in Operations and Maintenance stage of the system lifecycle.

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CRIS follows Information Technology Lifecycle Management 1.0 (ITLM), which
incorporates data integrity, privacy and security within each ITLM phase as defined by the DHS
Chief Information Officer (CIO).

9.3

Does the project employ technology which may raise
privacy concerns? If so please discuss their
implementation.

CRIS is a web-based application and as such is susceptible to privacy concerns. CRIS is
operating in accordance with Office of Management and Budget (OMB) M-04-04, EAuthentication Guidance for Federal Agencies. CRIS has an E-Authentication Assurance level of 1.
System security and information privacy for CRIS is achieved through several mechanisms
including:
Socket level encryption and authentication: All Internet data transmissions associated
with CRIS is encrypted via Secure Sockets Library (SSL), which uses public key technology to
negotiate a session key and cryptographic algorithms (based on the Date Encryption Standard
(DES), triple-DES, International Data Encryption Algorithm (IDEA), Rivest Code (RC) 4, RC2, and
Message Digest (MD) 5 hashes) between all CRIS clients and the CRIS web server. The public key
will be stored in a X.509 certificate that bears a digital signature from the USCIS’ certificate
authority.
Infrastructure network perimeter/border security: CRIS is deployed within the
Department of Justice Data Center (JDC-W) and leverages infrastructure and network services it
provides, such as Protocol Filtering, Internet Protocol (IP) Address Filtering, Transmission Control
Protocol/User Datagram Protocol (TCP/UDP) Port Filtering, Stateful Inspection, Packet Filtering,
Network Address Translation (NAT), Reverse Proxy, Encrypted and Secure Authentication.
Physical security:
Application-based user authentication and access Control: CRIS uses user IDs and
passwords to identify users and provide access control to application services. All application
services and database privileges are based on user roles. Passwords associated with the user
accounts and roles are stored within the application database in encrypted form. Password
encryption is implemented via a CRIS system Java utility class, which provides for just-in-time
encryption and decryption of passwords.
Access Control Lists: Access control lists that are checked against user identification
information stored within the session before any web page within the application is displayed
restrict direct URL access. This prevents users from bypassing the application menus and assigned
privileges by using the browser to directly navigate to web pages that have restricted access. CRIS
access control lists are maintained and used via database tables and Java classes that are called before
each page is loaded The system does not have the technology or the ability to monitor the activities
of individuals or groups beyond that required to accept address changes.

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Conclusion
CRIS is a web enabled system that offers customers of USCIS access to pending case status
information and estimated processing times; the ability to notify USCIS electronically of a change
of address; to record a service request by customer service representatives from applicants on issues
they have with their pending cases; and for USCIS personnel to document the resolution of the
reported pending case issue. CRIS enhances USCIS’s customer service capabilities and provides
timely case status information to customers on their pending applications and petitions.

Approval Signature

Original signed and on file with the DHS Privacy Office.
Hugo Teufel III
Chief Privacy Officer
Department of Homeland Security

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APPENDIX A – Privacy Act Notice
CRIS-Case Status Online
Authority: In accordance with the Paperwork Reduction Act of 1995, Public Law 104-13 and the Privacy
Act of 1974 as amended, Public Law 93-589 USCIS provides Case Status and Change of Address to
individuals and their representatives via a web-based application.
Purpose: The purpose of the collection of the information to setup an online Case Status account is to
enable U.S. Citizenship and Immigration Services to provide status updates on pending applications and
petitions to those individuals who have filed for benefits and wish to receive status updates electronically
via the Case Status Online system.
Routine Uses: The information will be used by and disclosed to DHS personnel and contractors or other
agents who need the information to assist in activities related to providing status information on pending
applications and petitions. Additionally, DHS may share the information with law enforcement or other
government agencies as necessary to respond to potential or actual threats to national security pursuant
to the agency’s published Privacy Policy and the routine uses outlined in the Benefits Information System
system of records notice, DHS-USCIS-007, September 29, 2008 73 FR 56596.
Disclosure: Furnishing this information is voluntary; however, failure to furnish the requested information
may prevent the ability of Case Status Online to send status updates on cases which are pending.

CRIS-Change of Address Online
Authority: The collection of alien address information is required by Section 265 of the Immigration and
Nationality Act (8 U. S.C. 1305).
Purpose: The data collected for a Change of Address notification is used by U.S. Citizenship and
Immigration Services for statistical and record purposes and may be furnished to Federal, State, local and
foreign law enforcement officials and intelligence agencies for national security purposes.
Routine Uses: The address information entered into Change of Address Online will be used by and
disclosed to DHS personnel and contractors or other agents who need the information to assist in
ensuring that address information is updated within the proper claims processing systems. Additionally,
DHS may share the information with law enforcement or other government agencies as necessary to
respond to potential or actual threats to national security pursuant to the agency’s published Privacy
Policy and the routine uses outlined in the Benefits Information System system of records notice, DHSUSCIS-007, September 29, 2008 73 FR 56596.
Disclosure: Furnishing this information is voluntary; however, failure to report a change of address is
punishable by fine or imprisonment and/or removal.