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 11

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 11

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

Form I-824, Application for Action on an Approved Application or Petition (OMB
NO.1615-0044)

Component:

U.S. Citizenship and
Immigration Services (USCIS)

Office or
Program:

Service Center Operations
(SCOPS)

Xacta FISMA
Name (if
applicable):

N/A

Xacta FISMA
Number (if
applicable):

N/A

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Update

Date first
developed:
Date of last PTA
update

N/A

Pilot launch
date:

N/A

September 30, 2013

Pilot end date:

September 30, 2015

ATO Status (if
applicable)

N/A

ATO
expiration date
(if applicable):

N/A

PROJECT OR PROGRAM MANAGER
Name:

Joe Dong

Office:

SAFE

Title:

Adjudications Officer

Phone:

202-272-8168

Email:

[email protected]

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

N/A

Phone:

N/A

Email:

N/A

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 11

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Updated PTA
Form I-824, Application for Action on an Approved Application or Petition is set to expire on September
30, 2015. The purpose of the revised Form I-824 and the instructions is to add USCIS ELIS Account
number fields for electronic filing to improve USCIS operations’ efficiency in the current technology &
system. In addition, Province, Postal Code, and Country fields were added under both physical & mailing
address sections to allow customers to file the Form I-824 abroad.
This revised form is also being updated to clarify areas of the instructions, to make them easier to
understand for the customer, and to incorporate standard language in the instructions/formatting required
by OMB.
Form I-824, Application for Action on an Approved Application or Petition
Applicants use Form I-824, Application for Action on an Approved Application or Petition, to file an
action for the approved underlying application or petition when the petitioner/applicant either changes his
or her nonimmigrant or immigrant status or needs a new action by USCIS or Department of State (DOS),
which is different form that originally requested. Applicants also use the form to request a duplicate
approval notice from USCIS or the U.S. Customs and Border Protection (CBP) of a petition or
application previously approved.
Form I-824 may be used in the following circumstances:
1. To request a duplicate approval notice;
2. USCIS to notify a new U.S. consulate through the DOS National Visa Center (NVC) or Kentucky
Consular Center (KCC) concerning the approval of a nonimmigrant visa petition or to notify a new
port of entry concerning the approval of a waiver application.
3. USCIS to notify a U.S. consulate through the DOS NVC that an individual’s status has been
adjusted to permanent resident based on an approved Form I-485 application;
4. USCIS to send an approved immigrant visa petition to the DOS NVC;
5. USCIS to notify the DOS that an individual has become a U.S. citizen through naturalization
CBP also collects and stores I-824 data to process requests for a duplicate approval notice. CBP’s
Admissibility Review Office records the I-824 information in the Automated Targeting System’s
Targeting Framework for case management purposes, as well as recording the issuance of an approved I824 in TECS to facilitate inspections at the border. A copy of the approval is sent to USCIS to be stored
in the A-File.
Relevant Information Technology
USCIS uses CLAIMS 3 to process Form I-817. The physical form and supplemental evidence is stored in
the Alien File or Receipt File.
2. Does this system employ any of the
following technologies:

Closed Circuit Television (CCTV)

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 11

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.

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

4. What specific information about individuals is collected, generated or retained?
Form I-824 is used to collect information about the petitioner/applicant of the underlying petition or
application, who requests USCIS to take either an action or to notify U.S. Department of State about the
petitioner/applicant’s new request of his or her immigrant benefit(s). USCIS and CBP also use the form
to request a duplicate approval notice of a previously approved petition or application.
Information collected about the petitioner/applicant include:

1

•

Full Name

•

Company or Organization Name

•

Alien Registration Number (A-Number , if applicable)

•

USCIS ELIS Account number

•

Social Security Number

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 5 of 11

•

Receipt Number

•

IRS Tax Number, if applicable

•

Physical and mailing Address

•

Telephone Number(s)

•

Email Address

•

Date of Birth

•

Country of Birth

•

Current/Recent Immigration Status

•

Certificate of Naturalization or Citizenship Number

•

Date of Signature

•

Signature

Information collected about the dependents includes:
•

Full Name

•

Date of Birth

•

Country of Birth

•

Country of Citizenship

Information collected about the representative and accredited representative includes:
•

Attorney State License Number

•

USCIS ELIS Account Number (if any)

Information collected about the form preparer includes:
•

Full Name

•

Business or Organization Name

•

Mailing Address

•

Phone Number

•

Email Address

•

Signature

Information collected about the interpreter includes:
•

Full Name

•

Business or Organization Name

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 11

•

Mailing Address

•

Phone Number

•

Email Address

•

Signature
No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used:

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:

•

Alien Registration Number (A-Number , if
applicable)

•

USCIS ELIS Account number

•

Receipt Number

•

Name and Date of Birth

No.
Yes.
INA 264(f) (8 U.S.C. 1304(f)) provides the
Secretary of Homeland Security with the specific
authority to collect SSNs of those applying for
immigration benefits. USCIS collects the SSN to
facilitate and expedite the adjudication of the
applicant’s request for a Form I-824 Application for
Action on an Approved Application or Petition. The
SSN information is used to establish and
corroborate the applicant’s identity.
The SSN information collected within the Form I824 application is also used to assist DHS in
enforcing the immigration laws of the United States
by providing timely and accurate information about
persons who are subject to those laws. USCIS
personnel conduct background security checks on
applicants for the purpose of determining whether
the applicant has established eligibility for the
benefit requested. Because the I-824 is typically a
non-interview, paper-based adjudication, the SSN is
especially useful and provides significant
information to verify an applicant’s identity and
his/her claim to eligibility: providing a critical tool
for more accurate and appropriate adjudication

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 11

determinations for USCIS and the applicant.
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 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.
N/A

No.
Yes. If yes, please list:
5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?

Form I-824 data is stored in USCIS CLAIMS 3.
CBP stores I-824 data in the Automated Targeting
System’s Targeting Framework for case
management purposes, and records the issuance of
an approved I-824 in TECS to facilitate inspections
at the border.
No.

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,
3

Yes. If yes, please list:
USCIS will share the data on Form I-824 including
all supporting documents with DOS. This is
necessary because without sharing, DOS is unable
to process the applicant’s request and to issue a visa
to the beneficiary of the I-824 if he or she is eligible
for the visa benefit.
Existing
DHS/USCIS-DOS/Bureau of Consular Affairs

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.
4
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.

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 11

MOU which allows DOS and DHS to exchange visa
and immigration data.

etc.)?
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?

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.
Yes. If yes, please list:

Not applicable.
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:
Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

Moderate

High

Undefined

Availability:
Low
Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)

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 9 of 11

Component Privacy Office Reviewer:

Jenny Hoots

Date submitted to Component Privacy
Office:

February 5, 2015

Date submitted to DHS Privacy Office:

March 12, 2015

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
The USCIS Office of Privacy recommendation is to designate Form I-824 as privacy sensitive with
coverage under the following privacy compliance documentation:
PIA
•

DHS/USCIS/PIA-016 - Benefits Processing of Applicants other than Petitions for Naturalization,
Refugee Status, and Asylum (CLAIMS 3), which covers the processing and adjudication of Form
I-824.

•

DHS/CBP/PIA-006(b) - Automated Targeting System (ATS) Update, which covers which covers
the collection and use of information for case management purposes.

•

DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing, which covers the
collection and use of information to facilitate inspections at the border.

SORN
•

DHS/USCIS-001 - Alien File, Index, and National File Tracking System of Records, which
covers the collection, use, and maintenance of the physical application and supplemental
documents.

•

DHS-USCIS-007 - Benefits Information System, which covers the collection, use, and storage of
benefit applications.

•

DHS/USCIS-015 - Electronic Immigration System-2 Account and Case Management System of
Records, which covers the collection, use, and storage of the ELIS Numbers.

•

DHS-CBP-006 - Automated Targeting System, which covers the collection and use of
information for case management purposes.

•

DHS-CBP-011 - U.S. Customs and Border Protection TECS, which covers the collection and use
of information to facilitate inspections at the border.

Please note that USCIS is updating the DHS-USCIS-007 Benefit Information System SORN to cover the
collection, use, and maintenance of preparer and interpreter information.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Lindsay Lennon

PCTS Workflow Number:

1077571

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 10 of 11

Date approved by DHS Privacy Office:

April 28, 2015

PTA Expiration Date

April 28, 2018
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

Form/Information Collection
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.
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:

If covered by existing PIA, please list: DHS/USCIS/PIA-016 - Benefits Processing of
Applicants other than Petitions for Naturalization, Refugee Status, and Asylum (CLAIMS
3), DHS/CBP/PIA-006(b) - Automated Targeting System (ATS) Update, and
DHS/CBP/PIA-009 TECS System: CBP Primary and Secondary Processing
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/USCIS/ICE/CBP-001 - Alien File, Index,
and National File Tracking System of Records, DHS/USCIS-007 - Benefits Information
System, DHS/USCIS-015 - Electronic Immigration System-2 Account and Case
Management System of Records, DHS-CBP-006 - Automated Targeting System, and
DHS/CBP-011 - U.S. Customs and Border Protection TECS

DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The Form I-824 is used for previously approved applications and petitions. USCIS may send this form to
CBP or DOS. USCIS is updating the Form I-824 to include ELIS number, and province, postal, and

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 11 of 11

country codes.
PRIV agrees with USCIS Privacy that USCIS’s collection, use, and maintenance of the form is covered
by the CLAIMS 3 PIA and A-File, BIS, and ELIS SORNs. PRIV agrees with USCIS and CBP Privacy’s
recommendations that the ATS and TECS PIAs and ATS and TECS SORNs provide privacy compliance
documentation coverage for the form.
The A-File SORN, routine use O, permits USCIS to share information with the Department of State in
processing petitions and applications under the INA and other immigration laws.