Pta

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
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:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your 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: 202-343-1717.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 2 of 8

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Ombudsman Case Assistance Form and Online System

Component:

Management (MGMT)

Office or
Program:

DHS HQ CISOMB

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Choose an item.

Date first
developed:
Date of last PTA
update

September 1, 2011

Pilot launch
date:

September 1, 2012

September 26, 2013

Pilot end date:

September 28, 2012

ATO Status (if
applicable)

Complete

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Gary Merson

Office:

DHS HQ CISOMB

Title:

Deputy Director

Phone:

202-357-8103

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

Raymond Mills (ISSO Liaison for CISOMB with DHS HQ CIO)

Phone:

202-731-5356

Email:

[email protected]

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 3 of 8

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Choose an item.
The Citizenship and Immigration Services (CIS) Ombudsman was created under section 452 of the
Homeland Security Act of 2002 (Public Law 107-296) to: (1) assist individuals and employers in
resolving problems with the U.S. Citizenship and Immigration Services (USCIS); (2) to identify areas in
which individuals and employers have problems in dealing with USCIS; and (3) to the extent possible,
propose changes in the administrative practices of USCIS to mitigate problems. There is no change in
the information being collected, however there have been cosmetic changes to the form including
punctuation, formatting, sequencing of information, and text changes to make the form more
understandable and streamlined for use by respondents.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology please stop here and contact the DHS
Privacy Office for further guidance.

Closed Circuit Television (CCTV)
Social Media
Web portal 1 (e.g., SharePoint)
Contact Lists
None of these

3. From whom does the Project or
Program collect, maintain, use, or
disseminate information?
Please check all that apply.

This program does not collect any personally
identifiable information 2
Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS
Employees of other federal agencies

1

Informational and collaboration-based portals in operation at DHS and its components that collect, use, maintain, and share
limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who
seek to gain access to the portal.
2
DHS defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the
identity of an individual to be directly or indirectly inferred, including any information that is linked or linkable to that individual,
regardless of whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to
the Department. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial
harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 4 of 8

4. What specific information about individuals is collected, generated or retained?
The AMENDED 7001 has the sections arranged in the following order:
1.
Name: Please identify the name of the individual or employer (applicant/ beneficiary/petitioner)
encountering or difficulties with USCIS. Do not enter the attorney/law firm's name here.
2.
Date of Birth: Country of Birth: Country of Citizenship:
3.
Alien Registration Number (A-Number);The A-number appears in the following format: A123456-789.
4.
Contact Information: Please provide the contact information of the individual or employer
(applicant/beneficiary/petitioner) encountering difficulties with USCIS. Please include the primary EMail address for the Ombudsman to provide updates.
5.
Applications/Petitions Filed: List all applications and/or petitions pending with USCIS related to
your case inquiry.
6.
Type of Immigration Benefit Sought: Please provide the type of immigration benefit sought from
USCIS.
7.
Reason for Inquiry/Case Assistance Request: Check all that apply. Provide a description in
section 8 and add documentation related to your inquiry.
8.
Description of your Case Problem: Describe the difficulties experienced with USCIS including
all responses USCIS provided. Attach relevant correspondence concerning actions taken to resolve the
issue before submitting with the Ombudsman's Office including: receipt notices; requests for evidence;
decisions; notices and any other correspondence from USCIS about your case. Attach additional pages if
needed.
9.
Prior Actions Taken to Remedy the Problem:
Check all that apply and provide the additional information requested for each selection in the space
provided. Note that if selecting Option a "Visited USCIS My Case Status at www.uscis. gov", you must
indicate what additional actions (b through g) were taken to remedy the problem before submitting the
form to the Ombudsman
a.
Visited USCIS My Case Status at www.uscis.gov.and
b. Contacted the National Customer Service Center (NCSC) for information and/or assistance regarding
this case at their toll-free number 1-800-375-5283. Provide SRMT Number:
c. Attended an InfoPass Appointment with USCIS.
Provide InfoPass Number:
d. Sent an E-mail to USCIS. Provide date E-Mail sent: Provide USCIS E-mail address:
e. Contacted a U.S. Government Department or Agency for assistance. Provide name and contact
information:
f. Contacted a U.S. Congressional Representative for assistance. Provide name and contact information:
g. Other. Please describe
10.
Person Preparing This Form:

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 5 of 8

Please indicate who is completing this form
11.
Attorney or Accredited Representative:
Please complete this section if you are an attorney, a representative of an organization, an accredited
representative, or anyone else preparing this form on behalf of the individual or employer encountering
difficulties with USCIS. Please attach copy of your Form G-28
12.
Consent: Please note that if you are the beneficiary of an immigration petition, consent of the
individual or employer that submitted the petition on your behalf is required. The petitioner must sign.

4(a) Does the project, program, or system
retrieve information by personal identifier?
4(b) Does the project, program, or system
use Social Security Numbers (SSN)?
4(c) If yes, please provide the specific legal
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
an information technology/system, does it
relate solely to infrastructure?

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used: 7001 intake number, A-Number
No.
Yes.
Click here to enter text.

Click here to enter text.

No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?
4(f) If header or payload data 3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?
3

No.

When data is sent over the Internet, each unit transmitted includes both header information and the actual data being sent. The
header identifies the source and destination of the packet, while the actual data is referred to as the payload. Because header
information, or overhead data, is only used in the transmission process, it is stripped from the packet when it reaches its
destination. Therefore, the payload is the only data received by the destination system.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 6 of 8

Yes. If yes, please list:
DHS USCIS
6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?
6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?

No.
Yes. If yes, please list:
Click here to enter text.
Choose an item.
Please describe applicable information sharing
governance in place:

No.
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?

Yes. If yes, please list: CISOMB staff receive
training in the Online Case Assistance Form and
with the Citizenship and Immigration Services
Ombudsman (CISOMB) Case Assistance Analytics
and Data Integration (CAADI) system that manages
all of the intake data.

8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have
requested access to their PII?
9. Is there a FIPS 199 determination? 4

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained:
Unknown.
No.
Yes. Please indicate the determinations for each
of the following:

4

Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

High

Undefined

Moderate

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 Xacta.
4
FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 7 of 8

Availability:
Low
Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Click here to enter text.

Date submitted to Component Privacy
Office:

Click here to enter a date.

Date submitted to DHS Privacy Office:

Click here to enter a date.

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
Click here to enter text.

(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Lindsay Lennon

PCTS Workflow Number:

1048615

Date approved by DHS Privacy Office:

March 10, 2015

PTA Expiration Date

March 10, 2018
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Choose an item. If “no” PTA adjudication is complete.
Choose an item.
If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
New information sharing arrangement is required.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 8 of 8

DHS Policy for Computer-Readable Extracts Containing Sensitive PII
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.
System covered by existing PIA
PIA:

SORN:

If covered by existing PIA, please list: DHS/CISOMB/PIA-001 – Virtual Ombudsman
System
System covered by existing SORN

If covered by existing SORN, please list: DHS/CISOMB-001 Virtual Ombudsman System
April 13, 2010, 75 FR 18857
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
This PTA covers the Form 7001. CIS Ombudsman has made cosmetic changes to the form, and there are
no changes to the data collected and how it is used. PRIV finds that the Form 7001 continues to receive
coverage under the DHS/CISOMB/PIA-001 PIA and DHS/CISOMB/-001 SORN.