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 9

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 9

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

Form N-300, Application for Declaration of Intention

Component:

U.S. Citizenship and
Immigration Services (USCIS)

Office or
Program:

Field Operations Directorate

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

N/A

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Modification

Date first
developed:
Date of last PTA
update

Click here to enter a date.

Pilot launch
date:

N/A

June 10, 2009

Pilot end date:

N/A

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

N/A

PROJECT OR PROGRAM MANAGER
Name:

Ely P. Borjal

Office:

Citizenship Branch, FOD

Title:

Adjudications Officer

Phone:

202 272 8679

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 9

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: New PTA
The Form N-300, Application for Declaration of Intention is used by permanent residents to file a
Declaration of Intention to become a United States citizen.
While USCIS does not require an individual to file this form to be eligible to become a U.S. Citizen,
some states do. In some states, an individual must file the N-300 if they intend to do business with the
state. For example, the state of Oregon requires lawful permanent residents (LPR) to have executed the
intention to become a United States citizen in order to obtain a ‘concealed weapons permit’. While some
states require the submission of this form to USCIS, USCIS is solely responsible for adjudicating the
form.
Upon receiving the N-300, USCIS issue a receipt notice to the individual notifying them that USCIS has
received their Declaration of Intent to become a USCIS Citizen.
The updated N-300, Application for Declaration of Intention has no substantive changes except the
addition of interpreter, translator, acknowledgment of Application Support Center (ASC) appointment of
applicant and preparer of the form.
Relevant Information Technology
There is no case management system for this form. A copy of the form N-300, Application for
Declaration of Intention is maintained in the A-file.

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?
1

This program does not collect any personally
identifiable information 2

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

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 9

Please check all that apply.

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?
Information collected from the applicant:
• First name
• Middle name or initial
• Last name
• Date of birth
• Mailing and physical addresses
• Social security number
• Legal permanent resident date
• Country of birth
• Nationality
• Telephone numbers
• Email address,
• USCIS ELIS Account Number
Information collected from the interpreter:
• First name
• Middle name or initial
• Last name
• Address
• Telephone numbers
• Email address
• The Attorney State Bar Number (if applicable)
• The Attorney or Accredited Representative USCIS ELIS Account Number
Information collected from the Preparer:
• First name
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 9

•
•
•
•
•
•

Last name
Business or organization name
Mailing address
Telephone number
Fax number
Email address

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: Receipt numbers that references the applicants
legal permanent resident number
Full name, (alone and also combined with date of
birth, country of birth, country of citizenship,
etc.),A-number, Receipt Number, Social Security
Number, Phone Number
No.
Yes.
INA 334 and 8 CFR 334.11, to be use for proof of
residency, physical presence evidence, and proof of
legal permanent status.
SSN can be matched with an income tax return filed
yearly for earnings and proof of payment of taxes.
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

3

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 9

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

No.
Yes. If yes, please list:
Click here to enter text.

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.)?
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:
Click here to enter text.
N/A

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

High

Undefined

Moderate

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.
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 9

Availability:
Low
Moderate

High

Undefined

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

Catherine Catanzaro Shorten

Date submitted to Component Privacy
Office:

August 20, 2015

Date submitted to DHS Privacy Office:

September 1, 2015

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
The USCIS Privacy Office recommendation is to designate Form N-300, Application for Declaration of
Intention as a privacy sensitive program. While the N-300 is not processed in a case management system,
like all A-file content, this form is subject to digitization. Therefore, we recommend coverage under the
Integrated Digitization Document Management Program (IDDMP) PIA.
Furthermore, we recommend coverage under the DHS/USCIS-001 – Alien File, Index, and National File
Tracking System of Records June 13, 2011, (76 FR 34233).
USCIS is also drafting an updating Privacy Act Statement to add to the form.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Gina Mostafaie

PCTS Workflow Number:

1105128

Date approved by DHS Privacy Office:

October 16, 2015

PTA Expiration Date

October 16, 2018
DESIGNATION

Privacy Sensitive System:
Category of System:

Yes

If “no” PTA adjudication is complete.

Form/Information Collection
If “other” is selected, please describe: Click here to enter text.

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 9

Determination:

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-003(a) - Integrated Digitization Document Management Program
(IDDMP), September 24, 2013
-DHS/USCIS/PIA-016 - Benefits Processing of Applicants other than Petitions for
Naturalization, Refugee Status, and Asylum (CLAIMS 3)
System covered by existing SORN

If covered by existing SORN, please list:
-DHS/USCIS/ICE/CBP-001 – Alien File, Index, and National File Tracking System of
Records, November 21, 2013, 78 FR 69864;
-DHS/USCIS-007 - Benefits Information System September 29, 2008 73 FR 56596
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The Form N-300, Application for Declaration of Intention, is used by permanent residents to become a
United States citizen. This form has been updated and now contains interpreter, translator,
acknowledgement of Application Support Center (ASC) appointment of applicant and the form preparer.
USCIS is only responsible for adjudicating the form.
USCIS is submitting the Form N-300 because this form collects and maintains PII from the member of
the public and therefore requiring PIA and SORN coverage. PRIV concurs that the Form N-300 requires
language to include Privacy Act Statement since its collecting PII.
This information is covered by following existing PIAs:
-DHS/USCIS/PIA-003(a) - Integrated Digitization Document Management Program (IDDMP),
September 24, 2013; and
-DHS/USCIS/PIA-016 - Benefits Processing of Applicants other than Petitions for Naturalization,
Refugee Status, and Asylum (CLAIMS 3).
SORN:

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 9

PRIV finds that the information collected is covered by the two SORNs listed below.
-DHS/USCIS/ICE/CBP-001 – Alien File, Index, and National File Tracking System of Records,
November 21, 2013, 78 FR 69864; and
-DHS/USCIS-007 - Benefits Information System September 29, 2008 73 FR 56596.