Pia 41

Privacy Impact Assessment
for the

U.S. Citizenship and Immigration Services
Electronic Immigration System
(ELIS-1)
Temporary Accounts and Draft Benefit Requests
DHS/USCIS/PIA-041
May 16, 2012
Contact Point
Donald Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
(202) 272-8000
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 1

Abstract
U.S. Citizenship and Immigration Services (USCIS) is the component of the Department
of Homeland Security (DHS) that oversees lawful immigration to the United States. USCIS is
transforming its operations by creating a new electronic environment known as the USCIS
Electronic Immigration System (USCIS ELIS), which allows individuals requesting a USCIS
benefit to register online and submit certain benefit requests through the online system. This
system will improve customer service; increase efficiency for processing benefits; better identify
potential national security concerns, criminality, and fraud; and create improved access controls
and better auditing capabilities. This Privacy Impact Assessment (PIA) is being conducted
because USCIS ELIS collects and uses personally identifiable information (PII). This new
electronic environment is divided into three distinct processes: 1) Temporary Account and Draft
Benefit Requests; 2) Account and Case Management; and 3) Automated Background Functions.
This PIA addresses the Temporary Account and Draft Benefit Requests process by describing
how Applicants or their Representatives can create a temporary account, draft a benefit request,
and submit or abandon that request. USCIS is publishing separate PIAs for the other two USCIS
ELIS processes concurrent with this PIA.

Overview
U.S. Citizenship and Immigration Services (USCIS) is the component of the Department
of Homeland Security (DHS) that oversees lawful immigration to the United States. USCIS is
transforming its operations by creating a new electronic environment known as the USCIS
Electronic Immigration System (USCIS ELIS), which allows individuals requesting a USCIS
benefit to register online and submit certain benefit requests. This system will improve customer
service; increase efficiency for processing benefits; better identify potential national security
concerns, criminality, and fraud; and create improved access controls and better auditing
capabilities.
Applicants and petitioners (Applicants); co-applicants, beneficiaries, derivatives,
dependents, or other persons on whose behalf a benefit request is made or whose immigration
status may be derived because of a relationship to an Applicant (Co-Applicants); and/or their
attorneys and representatives recognized by USCIS and/or accredited by the Board of
Immigration Appeals (Representatives); may create individualized online accounts. These online
accounts help Applicants and their Representatives file for benefits, track the status of open
benefit requests, schedule appointments, change their addresses and contact information, and
receive notices and notifications regarding their cases. Through USCIS ELIS, individuals may
submit evidence electronically. Once an individual provides biographic information in one
benefit request, USCIS ELIS uses that information to pre-populate certain fields in future benefit
requests. This eases the burden on an individual so he or she does not have to repeatedly type in
the same information each time the individual is seeking a benefit from USCIS.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 2

USCIS is publishing three PIAs to cover the following three distinct processes of this
new electronic environment and the privacy and security protections incorporated into USCIS
ELIS: 1
1. Temporary Accounts and Draft Benefit Requests: The DHS/USCIS/PIA-041
Temporary Accounts and Draft Benefit Requests (USCIS ELIS-1) PIA addresses
temporary data provided by Applicants or Representatives. All Applicants first
interact with USCIS ELIS by creating a temporary account, setting notification
preferences, and drafting their first benefit request. If a first-time Applicant does
not begin drafting a benefit request within 30 days of opening a temporary
account, USCIS ELIS deletes the temporary account. If he or she does not submit
the benefit request within 30 days of starting a draft benefit request, USCIS ELIS
deletes the temporary account and all draft benefit request data. If a first-time
Applicant submits the benefit request within 30 days, USCIS ELIS changes the
status of the account from temporary to permanent, at which point it is processed
according to the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2)
PIA detailed below. Applicants with permanent USCIS ELIS accounts or
Representatives may also draft benefit requests. USCIS ELIS deletes all draft
benefit requests, both first-time and existing Applicants, if they are not submitted
within 30 days of initiation.
2. Account and Case Management: The DHS/USCIS/PIA-042 Account and Case
Management (USCIS ELIS-2) PIA addresses the activities undertaken by USCIS
after Applicants or Representatives submit a benefit request. USCIS ELIS uses
information provided on initial and subsequent benefit requests and subsequent
collections through the Account and Case Management process to create or
update USCIS ELIS accounts; collect any missing information; manage
workflow; assist USCIS adjudicators as they make a benefit determination; and
provide a repository of data to assist with future benefit requests. In addition,
USCIS ELIS processes and tracks all actions related to the case, including
scheduling appointments and issuing decision notices and/or proofs of benefit.
3. Automated Background Functions: The DHS/USCIS/PIA-043 Automated
Background Functions (USCIS ELIS-3) PIA addresses the actions USCIS ELIS
takes to detect duplicate and related accounts, compare and append information
from existing immigration benefit data previously collected by USCIS, and
identify potential national security concerns, criminality, and fraud to ensure that
serious or complex cases receive additional scrutiny.

1

The three PIAs covering USCIS ELIS: DHS/USCIS/PIA-041, DHS/USCIS/PIA-042, and
DHS/USCIS/PIA-043, were conducted concurrently and are all available at
http://www.dhs.gov/files/publications/gc_1279308495679.shtm.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 3

This Temporary Accounts and Draft Benefit Requests PIA addresses the temporary
account process for first-time Applicants in USCIS ELIS and the draft benefit request process for
all Applicants and Representatives. For both temporary and permanent accounts, USCIS ELIS
retains information in a draft benefit request until it is submitted or expires. Since USCIS does
not have an official need to know the information until it is submitted, USCIS ELIS segregates
temporary account and draft benefit request information from permanent information in USCIS
ELIS. This segregation of data prevents USCIS personnel (aside from USCIS ELIS System
Administrators as part of their system maintenance duties) from viewing this temporary data until
the Applicant or Representative submits the benefit request. USCIS will delete the Applicant’s
temporary account information from USCIS ELIS if the Applicant or Representative does not
submit the benefit request within 30 days of initiation of the benefit request. If the Applicant
submits the benefit request, USCIS converts the Applicant’s temporary account to a permanent
account and processes the benefit request information according to the guidelines set forth in the
DHS/USCIS/PIA-042 USCIS ELIS Account and Case Management (ELIS-2) PIA and
DHS/USCIS/PIA-043 USCIS ELIS Automated Background Functions (ELIS-3)PIA. 2
USCIS ELIS allows Applicants who have not previously submitted a benefit request
through USCIS ELIS to create an account so they may draft and submit benefits. USCIS does not
need to know the account information before the request is submitted because the Applicant has
not formally requested anything of USCIS. Further, information at this pre-submittal stage may
not be accurate or ready for submission. First-time Applicant accounts are temporary in USCIS
ELIS until the Applicant formally submits a benefit request.
For Representatives, USCIS ELIS only creates permanent accounts; it does not create
temporary accounts. This allows Representatives to work on several clients’ cases at the same
time and/or draft benefit requests for multiple clients. USCIS will maintain and use those
Representative accounts according to the processes set forth in the DHS/USCIS/PIA-042 Account
and Case Management (ELIS-2) PIA.
Establishing a Temporary Account
To create a temporary USCIS ELIS account, an Applicant may visit
https://elis.uscis.dhs.gov and select the option indicating that he or she is a new user. New users
may also navigate to the account creation page through the “Forms” section on www.uscis.gov
for forms that may be processed through USCIS ELIS. After acknowledging a Privacy Act
notice, the Applicant is prompted to provide his or her email address on the “Create Account”
page. USCIS ELIS checks to ensure there is no existing account associated with the email
address, and sends an email with a confirmation link to the email address provided. 3 The link
automatically connects to USCIS ELIS and prompts the Applicant to create a password and
choose a second form of authentication (e.g., challenge questions, a PIN sent via SMS text
2

See DHS/USCIS/PIA-042 Account and Case Management and DHS/USCIS/PIA-043 Automated
Background Functions PIAs at www.dhs.gov/privacy.
3
Applicants must activate their account within five days of receiving the email with the confirmation link.
If the Applicant does not complete this account registration process within five days, the temporary account
will be deleted and the Applicant must start the process over if he or she wishes to file a benefit request.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 4

message to a mobile phone, or a PIN sent via automated voice call to the home or work phone
number provided). This minimal information (email address, password, challenge questions, and
optional phone number) is all that is required for an Applicant to establish a temporary account.
Following the creation of a temporary account, USCIS ELIS informs the Applicant that the
temporary USCIS ELIS account will be deleted after 30 days if he or she does not begin drafting
a benefit request within that time period. Once an Applicant with a temporary account begins
drafting a benefit request, a new 30-day clock begins before USCIS ELIS deletes the temporary
account.
Benefit Requests Drafted by the Applicant
After an Applicant has successfully registered his or her account, he or she may log in to
USCIS ELIS and begin drafting a benefit request by selecting a benefit type. To establish the
Applicant’s notification preferences, USCIS ELIS asks the Applicant how he or she wishes to
receive notifications regarding changes to his or her account and/or benefit request (via postal
mail, email, and/or SMS text message).
Based on the benefit type selected, USCIS ELIS guides the Applicant through a series of
screens that ask for information required to determine benefit eligibility. USCIS ELIS modifies
the questions based on the requested benefit and the Applicant’s circumstances when asking
questions. For instance, if the Applicant indicates that he or she is including family members in
the benefit request, USCIS ELIS asks for information about the Applicant’s family. If the
individual does not indicate that he or she is including a family member in the benefit request,
USCIS ELIS does not display the screens asking for family information. If the Applicant has a
Preparer assisting the Applicant when the Applicant is completing the benefit request, USCIS
ELIS also asks for that Preparer’s information. USCIS ELIS does not allow for Preparers to open
accounts and edit benefit requests as it does for Applicants and Representatives.
An Applicant may not have all of the required information immediately available when
drafting a benefit request, so USCIS ELIS permits the Applicant to save the partially-completed
benefit request as a draft for 30 days. This 30-day period begins once the Applicant begins
drafting his or her benefit request. If the Applicant or a Representative does not complete and
submit the benefit request within 30 days, USCIS deletes the draft request and deletes the
Applicant’s account if it is temporary (i.e., if the Applicant has not previously submitted a benefit
request in USCIS ELIS.)
As the Applicant drafts a benefit request, USCIS ELIS notifies the Applicant if the data
entered does not meet the data field format (e.g., letters in a phone number field). Each screen
that asks for information has tips with helpful hints and answers to common questions to further
assist the Applicant through the draft benefit request. As USCIS ELIS develops, it will notify the
Applicant, if it is evident from the information provided, that the Applicant is likely ineligible for
the benefit under certain circumstances. For example, if an Applicant begins filling out Form I821 Application for Temporary Protected Status, but claims citizenship of a country that does not
have that temporary protected status, USCIS ELIS warns the individual that the country is not
among those countries designated for Temporary Protected Status.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 5

During the drafting of a benefit request, Applicants may also upload scanned original
documents to satisfy evidentiary requirements associated with the benefit request. Depending on
the type of benefit request, USCIS ELIS asks for different types of documents to satisfy different
evidentiary requirements, including identity, citizenship, dates and manner of entry into the
United States, relationships, financial stability, and other eligibility criteria. USCIS ELIS
provides instructions on how to scan these documents and upload them in commonly accepted
formats (e.g., .bmp, .gif, .jpg, .pdf, .tif.)
If the Applicant has previously submitted a benefit request through USCIS ELIS, data
from the Applicant’s account and previous benefit requests pre-populates certain fields on the
current draft benefit request so the Applicant does not have to repeat the same information
previously provided when submitting his or her new benefit request. The Applicant will also be
able to choose if he or she wants to re-use documentary evidence previously scanned into the
system for subsequent benefit requests. If the pre-populated information is no longer accurate, the
Applicant may change certain information in his or her account. Once submitted, the new
information will be used to pre-populate future benefit requests.
After the Applicant has completed the benefit request and uploaded the required
evidence, USCIS ELIS displays a PDF of the completed benefit request to allow the Applicant to
review his or her responses before submission. If any information is incorrect, the Applicant can
go back and make the necessary corrections. If the benefit request is accurate and complete,
USCIS ELIS guides the Applicant through the E-signature process, which includes a Privacy Act
statement and attestation that the benefit request is complete and the responses are true and
accurate. USCIS ELIS also notifies the Applicant that the Internet Protocol (IP) address and
browser information of the computer will be collected at the time of submission.
In addition to providing eligibility information, the Applicant or Representative must also
pay the fee associated with the benefit request. To collect this fee, USCIS ELIS directs the
Applicant to provide payment via an embedded Pay.gov 4 screen after he or she e-signs the benefit
request. USCIS ELIS guides the Applicant through the payment process, which accepts credit
and debit cards, as well as e-checks. If the Applicant provides invalid credit card, debit card, or
e-check information, Pay.gov notifies USCIS ELIS, and USCIS ELIS sends the Applicant (via
the pre-selected preferred notification method) a notice that the benefit request has been rejected
for lack of payment. For partial or incomplete payments, USCIS ELIS will notify the applicant
(or the individual who made the payment on the applicant’s behalf) that the benefit request cannot
be processed until the proper payment has been submitted. USCIS ELIS will keep the draft
benefit request until 30 days from draft initiation, so the Applicant may correct the payment. If
Pay.gov indicates the payment information is valid, USCIS ELIS sends a notice to the Applicant
that the benefit request has been received for processing. Once the Applicant has provided his or
her e-signature and valid payment information, the information in the benefit request is formally
4

See U.S. Department of Treasury Financial Management Services Pay.gov PIA at
http://www.fms.treas.gov/pia/paygov_pia%20.pdf and Collections Records SORN,
https://www.federalregister.gov/articles/2003/02/04/03-2521/privacy-act-of-1974-as-amended-system-ofrecords.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 6

submitted and used according to the guidelines set forth in the DHS/USCIS/PIA-042 Account and
Case Management (ELIS-2) PIA and DHS/USCIS/PIA-042 Automated Background Functions
(ELIS-3) PIA. At this point, the temporary account and draft benefit request become permanent
in USCIS ELIS and is transitioned to the Account and Case Management system, is covered by
the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA.
Benefit Requests Drafted by the Representative
Through USCIS ELIS or the existing paper Form G-28 Notice of Entry of Appearance As
Attorney or Accredited Representative process, an Applicant may authorize a Representative to
act on his or her behalf during the benefit request process. Although the Representative’s account
is always permanent and thus subject to the DHS/USCIS/PIA-042 Account and Case Management
(ELIS-2) PIA, he or she may draft a benefit request on behalf of the Applicant; that draft benefit
request is subject to this PIA if not submitted after 30 days. This authorization may be terminated
by the Applicant at any time.
USCIS ELIS permits a Representative to log into USCIS ELIS and draft benefit requests
for his or her clients through the same process as Applicants up to the point of e-signature. When
the Form G-28 e-signature functionality becomes available, USCIS ELIS will incorporate the
Form G-28 into all benefit requests, so a Representative’s account information will automatically
pre-populate the Form G-28. After completing the benefit request, the Representative will review
the benefit request, acknowledge the Privacy Act statement, and attest to the benefit request’s
completeness, and that the Applicant’s responses are true and accurate. At this point, the benefit
request becomes permanent in USCIS ELIS and is transitioned to the DHS/USCIS/PIA-042
Account and Case Management (ELIS-2) PIA.
The Form G-28 enhanced e-signature functionality will not be available in the early
releases of USCIS ELIS. USCIS has created an interim solution until the functionality becomes
available where the Representative prints the benefit request with the included Form G-28 portion
for the Applicant’s review and physical signature. Once the Applicant has physically signed the
printed benefit request, the Representative scans and uploads the signature page as a piece of
evidence attached to the electronic benefit request.
As USCIS ELIS develops, a Representative will be able to draft a benefit request and
then electronically transfer it to the client’s account for the client to review and e-sign. USCIS
ELIS will accomplish this by generating a case passcode for the Representative to give to the
client. The client will use the case passcode to unlock the draft benefit request and to ensure that
the client’s Personally Identifiable Information (PII) is not divulged to the wrong person. A draft
benefit request that is not submitted within 30 days of initiation will be deleted from the system.
Requests Associated with Co-Applicants
Depending on the benefit request, Applicants may include Co-Applicants on their benefit
requests. USCIS ELIS sends a notice to the Applicant informing him or her that USCIS ELIS has
created an inferred account for the Co-Applicant and provides the Co-Applicant’s USCIS ELIS
account number. Pursuant to 8 CFR 103.2(a)(3), Co-Applicants may not access, modify, or

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 7

participate in benefit requests submitted by the Applicant. However, Co-Applicants may create
their own USCIS ELIS accounts and submit their own benefit requests. If the Co-Applicant later
requests a benefit individually, USCIS ELIS will merge the individual and inferred Co-Applicant
accounts.

Section 1.0 Authorities and Other Requirements
1.1

What specific legal authorities and/or agreements permit
and define the collection of information by the project in
question?

The primary legal authority supporting the collection of the information by USCIS is the
Immigration and Nationality Act (INA) of 1952, Pub. L. No. 82-414, §§ 101, 103, as amended.
The Homeland Security Act of 2002, Pub. L. No.107-296, 116 Stat. 2135 (2002), 6 U.S.C. § 112,
and the INA charge the Secretary of Homeland Security with the administration and enforcement
of the immigration and naturalization laws. The Secretary of Homeland Security has delegated
duties to USCIS pursuant to a DHS Management Directive MD 0150.1. DHS has also
promulgated regulations which permit the collection and processing of benefit requests online
entitled, “Immigration Benefits Business Transformation, Increment I.” 76 Fed. Reg. 53764
(August 29, 2011); “Immigration Benefits Business Transformation, Increment I; Correction.” 76
Fed. Reg. 73475, (Nov. 29, 2011).
The Government Paperwork Elimination Act (GPEA), Pub. L. No. 105-277, tit. XVII,
section 1703, 112 Stat. 2681, 2681-749 (Oct. 21, 1998), 44 U.S.C. § 3504 note, provides that,
when possible, federal agencies use electronic forms, electronic filing, and electronic submissions
to conduct agency business with the public. GPEA establishes the means for the use of electronic
signatures. Executive Order 13571, 75 Fed. Reg. 24339 (Apr. 27, 2011), requires federal
agencies to develop plans to streamline delivery of services and improve customer service by
exploring lower-cost, self-service options accessed by the Internet or mobile phone and improved
processes that deliver services faster and more responsively, reducing the overall need for
customer inquiries and complaints.

1.2

What Privacy Act System of Records Notice(s) (SORN(s))
apply to the information?

DHS/USCIS issued DHS/USCIS-014 – Electronic Immigration System-1 Temporary
Accounts and Draft Benefit Requests System of Records (76 FR 70730, November 15, 2011) to
cover the collection, maintenance, and use of this information. This system also contains internal
DHS user role information covered by DHS/ALL-004 - General Information Technology Access
Account Records System (GITAARS) (74 FR 49882, September 29, 2009).

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 8

1.3

Has a system security plan been completed for the
information system(s) supporting the project?

Yes. The USCIS ELIS System Security Plan includes the activities associated with the
Temporary Account and Draft Benefit Requests process. The Authority to Operate (ATO) was
issued on December 6, 2011 and is valid through July 2012, at which time USCIS expects to
issue a new 12-month ATO.

1.4

Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?

Yes. NARA approved schedule NI-566-11-002, which permits USCIS to retain an
Applicant’s temporary account and all draft benefit request information it collects in USCIS ELIS
for 30 days after initiation. After 30 days, USCIS ELIS deletes the information. Once an
Applicant or his or her Representative formally submits a benefit request, the Applicant’s account
and benefit request data becomes permanent and retained according to the DHS/USCIS/PIA-042
Account and Case Management (ELIS-2) PIA. See Section 5.1, below, for further discussion
about the retention of these records.

1.5

If the information is covered by the Paperwork Reduction
Act (PRA), provide the OMB Control number and the
agency number for the collection. If there are multiple
forms, include a list in an appendix.

USCIS has obtained approval from OMB for the data collections required for USCIS
ELIS accounts and benefit requests. Please see the Appendix for the list of approved forms and
OMB Control numbers.

Section 2.0 Characterization of the Information
2.1

Identify the information
disseminates, or maintains.

the

project

collects,

uses,

An Applicant’s temporary USCIS ELIS account registration information includes the
following:
•
•
•
•

Valid email address;
Password;
Challenge questions and answers; and
Telephone Number (optional).

All benefit requests include the following information about the Applicant or CoApplicant:
•

Alien Registration Number(s);

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 9

•
•
•
•
•
•
•
•
•
•

Full name and any alias(es) used;
Physical and mailing address(es);
Immigration status;
Date of birth;
Place of birth (city, state, and country);
Country of citizenship;
Gender;
Contact information (phone number[s], email address);
Military status;
Government-issued identification (e.g.; passport, driver's license):
o Document type,
o Issuing organization,
o Document number,
o Expiration date;

•
•
•
•

Benefit requested;
IP Address;
Internet browser information;
USCIS ELIS account number.5

The following information may be requested for benefit-specific eligibility:
•
•
•
•
•
•

•
•
•
•

5

U.S. State Department-Issued Personal Identification Number (PID);
Arrival/Departure Information;
Immigration history (citizenship/naturalization certificate number, removals,
explanations, etc.);
Family Relationships (e.g., Parent, Spouse, Sibling, Child, Other Dependents, etc., as
well as custody, guardianship, and other relationship issues);
USCIS Receipt/Case Number;
Personal Background Information (e.g., involvement with national security threats,
Communist party, torture, genocide, killing, injuring, polygamy, forced sexual
contact, limiting or denying others religious beliefs; service in military or other
armed groups; work in penal or detention systems, weapons distribution, combat
training);
Health Information (e.g., vaccinations, referrals, communicable disease, physical or
mental disorder, prostitution, drug abuse)
Education History;
Work History;
Financial Information (e.g., income, expenses, scholarships, savings, assets, property,
financial support, supporter information, life insurance, debts, encumbrances);

USCIS provides this information for returning Applicants. The Applicant will provide (or have prepopulated) his or her ELIS account number, once ELIS has assigned one, in the draft benefit request.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 10

•
•
•

Social Security Number, if applicable;
Supporting documentation as necessary (e.g., birth certificate, appeals or motions to
reopen or reconsider decisions); and
Criminal Records.

Preparer information includes:
•
•
•
•
•
•

Name;
Organization;
Physical and Mailing Addresses;
Phone and Fax Numbers;
Paid/Not Paid; and
Relationship to Applicant.

Representative information includes:
•
•
•
•
•
•
•
•
•

Name;
Law Firm/Recognized Organization;
Physical and Mailing Addresses;
Phone and Fax Numbers;
Email Address;
Attorney Bar Card Number or Equivalent;
Bar Membership;
Accreditation Date;
Board of Immigration Appeals (BIA) Representative Accreditation Expiration Date;
and
• Law Practice Restriction Explanation.

USCIS ELIS stores information provided by Applicants, Representatives, Preparers, and
Co-Applicants during the draft benefit request process for the purpose of enabling the Applicant
or Representative to reference, change, add, or delete information in preparation for submitting
the benefit request(s) to USCIS.
Although USCIS ELIS collects and stores temporary account and draft benefit request
information, it is segregated from other data, such as permanent case and account data (covered in
the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA.) This information is not
viewable by USCIS (aside from USCIS ELIS System Administrators as part of their system
maintenance duties) until the Applicant or Representative formally submits the benefit request,
thereby authorizing USCIS to process the information for the benefit sought.

2.2

What are the sources of the information and how is the
information collected for the project?

USCIS ELIS collects temporary account information directly from the Applicant. USCIS
ELIS assists the Applicant by confirming his or her email address and notifying the Applicant

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 11

about whether the data elements conform to the data field requirements (e.g., phone number fields
do not contain letters, passwords are sufficiently strong).
USCIS ELIS collects draft benefit request information directly from the Applicant or the
Representative. USCIS ELIS guides the Applicant or Representative through the process of
completing the benefit request and prompts the individual to provide the specific information that
is required for the requested benefit. If the benefit request requires supporting documents or other
evidence, the Applicant or Representative scans, uploads, and attaches the documents to the
benefit request.
After an Applicant has submitted his or her first benefit request, USCIS ELIS prepopulates certain fields in subsequent benefit requests with previously submitted information.
This process reduces errors and the burden that may result from an Applicant having to
repeatedly type in the same information.

2.3

Does the project use information from commercial sources
or publicly available data? If so, explain why and how this
information is used.

No. USCIS ELIS does not collect information from commercial or publicly available
data sources during the temporary account or draft benefit request process.

2.4

Discuss how accuracy of the data is ensured.

USCIS ELIS collects temporary account information directly from the Applicant to
ensure accuracy of the data. USCIS ELIS provides a basic assistance function to assist the
Applicant or Representative to identify problems with the information provided. For example, if
there is an email addresses without an “@” symbol, the individual will receive notice that the
email address is not in a proper format.
USCIS ELIS validates the Applicant’s email address to prevent the creation of duplicate
accounts. If the email address is already associated with another account, USCIS ELIS asks for
the account password. During the creation of a temporary account, USCIS ELIS instructs the
Applicant to use an email address that is only accessible by the Applicant. USCIS sends an email
confirmation to the email address the Applicant provides to ensure the email address is active and
accessible by the Applicant. The Applicant must click on a link provided in the confirmation
email to affirm that the email address is correct and active. If the Applicant does not respond to
the USCIS email address confirmation email within five days, USCIS deletes the account, and the
Applicant must repeat the process for creating an account in USCIS ELIS and filing a benefit
request.
USCIS ELIS ensures the accuracy of the information it collects during the drafting of a
benefit request by collecting the information directly from the Applicant, the Representative, or
the Preparer. Because the information is only in draft form, USCIS employees do not access or
verify the accuracy of the data (aside from USCIS ELIS System Administrators as part of their

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 12

system maintenance duties). USCIS checks the accuracy of the information once the Applicant
or Representative submits the benefit request, at which time it enters the Account and Case
Management process. 6
Although USCIS employees do not check the accuracy of draft benefit request data
before it is submitted, USCIS ELIS notifies Applicants and Representatives while they are
entering information into certain fields about potential inaccuracies and provides instructions for
resolving these potential inaccuracies. The draft benefit request process is designed to perform
minimal logical checks on draft data to ensure it is valid, accurate, and complete. These checks
include:
•

Edit Checks – The system performs edit checks on specific data fields to ensure a
valid data value is provided (e.g., telephone number consists of digits, not letters.)

•

“Required” Data Field Notations – The system will denote required data fields
with an asterisk (*). If the Applicant or Representative fail to input data in a required
data field, the system displays an error message and will not allow the Applicant or
Representative to proceed until the data field is completed.

•

Eligibility Error Messages – As USCIS ELIS develops, under certain
circumstances, the system will warn the Applicant if he or she is ineligible for the
requested benefit based on data included in the draft benefit request. For example, if
an Applicant begins filling out a Form I-821 Application for Temporary Protected
Status, but claims citizenship of a country that is not designated as a country whose
nationals are eligible for temporary protected status, USCIS ELIS will warn the
individual that the country is not among those listed for Temporary Protected Status.
USCIS ELIS will allow the Applicant or Representative to continue the application
process and submit the benefit request.

•

Warning Messages – The system automatically displays a message to the Applicant
or Representative when he or she fails to provide information in a “non-required”
data field. USCIS ELIS allows the Applicant or Representative to continue the
application process and submit the benefit request even if the Applicant or
Representative leaves the field blank.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk that information collected during the temporary USCIS
ELIS account creation process may be in excess of defined business needs and use.
Mitigation: Minimization of the collected data was a primary concern in establishing the
requirements for USCIS ELIS account registration. USCIS considered what an Applicant can do
6

See the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA and DHS/USCIS-043
Automated Background Functions (ELIS-3) PIA for additional information on USCIS’s process for
accessing and verifying information.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 13

using USCIS ELIS and the security needs of the system. During this process, USCIS determined
that only an email address, password, challenge questions, and an optional phone number were
required at this stage. Because an account could be created without a name, an Applicant’s name
is not collected at this stage. Because the account is not associated with a business need until a
benefit request is submitted, USCIS deletes the account after 30 days if the Applicant does not
begin drafting a benefit request. This minimizes the privacy risks attached to retaining
unnecessary information. If the Applicant begins drafting a benefit request within the initial 30
days, USCIS ELIS retains the temporary account information for 30 days after the Applicant
begins the draft.
Privacy Risk: There is a risk that data collected during the drafting of a benefit request
may exceed what is defined within business needs and use.
Mitigation: USCIS developed a detailed process to review what specific information is
needed to determine eligibility for a requested benefit. USCIS reviewed all the data elements that
are collected on every USCIS benefit request form. This review provided an understanding of
common data elements across all form types and allowed for the grouping of information into
standard categories for the benefit requests, which include: 1) the Applicant; 2) the benefit being
requested; 3) the eligibility for that benefit; 4) the other individuals included in the benefit
request; 5) the signatures; and 6) the Preparers and Representatives who assisted with the benefit
request process.
USCIS ELIS uses these standard sections for all benefit requests it processes. Sections 1
and 5 are the same for all benefit requests available in USCIS ELIS. Section 2 and Section 3 vary
depending on the type of benefit. Section 4 is only completed if multiple derivatives or
beneficiaries are included in the benefit request. The completion of Section 6 is only necessary if
there is a Representative or Preparer assisting in the benefit request process.
With the sections of the benefit request standardized, USCIS undertook a review of each
requested data element. USCIS reviewed the data to ensure that each data element is needed and
to increase processing efficiency, provide better customer service, and ensure the benefit is
provided only to qualified Applicants and Co-Applicants. Data that did not meet these
requirements were eliminated from the benefit request. As an example, Social Security numbers
are no longer requested for many benefit types. 7
USCIS ELIS deletes all draft benefit request information if it is not submitted within 30
days of initiation. This prevents USCIS from processing, handling, or retaining PII regarding an
individual that has no benefit request before USCIS.
Privacy Risk: There is a risk that incorrect or incomplete information in a draft benefit
request may be relied upon by USCIS and affect the decision on an Applicant or Co-Applicant’s
benefit request.
Mitigation: USCIS does not have a need to know the benefit request information until
7

See the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA and the Automated
Background Functions PIA for additional information.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 14

an Applicant attests to the accuracy and completeness of the information. USCIS ELIS
segregates this draft benefit request data from other data in USCIS ELIS to prevent adjudicators
or others from using information that has not been formally submitted by the Applicant. While
all data in the system, including temporary account and draft benefit request data, is accessible by
USCIS ELIS system administrators, these users may only access the data for system maintenance
and stability purposes. System Administrators are not allowed to process or act upon any of the
information in the draft benefit request or temporary account. USCIS ELIS logs any access to
this data to ensure the integrity of the system.
Privacy Risk: There is a risk that information collected from an Applicant about a CoApplicant may be inaccurate. This risk is compounded by the Co-Applicant’s lack of access to
information about his or her in USCIS ELIS.
Mitigation: Pursuant to 8 C.F.R 103.2(a)(3), Co-Applicants may not access, modify, or
participate in benefit requests submitted by the Applicant. However, Co-Applicants may create
their own USCIS ELIS accounts and submit their own benefit requests. If the Co-Applicant later
requests a benefit as an Applicant, USCIS ELIS merges the individual and Co-Applicant
accounts. Co-Applicants would then be able to see data provided on previous benefit requests.
Also, USCIS always allows an individual to contest information if it will be the basis for denying
a benefit request, including information provided on a previous benefit request by the Primary
Applicant.

Section 3.0 Uses of the Information
3.1

Describe how and why the project uses the information.

USCIS ELIS collects and uses temporary USCIS ELIS account information to establish a
unique USCIS ELIS account. USCIS uses the email address to verify its validity during the email
confirmation process and to detect duplicate USCIS ELIS accounts by sending a confirmation
email. The temporary account allows the Applicant to draft and submit benefit requests. USCIS
ELIS uses the temporary account contact information to send a warning to the Applicant that the
account and draft benefit request are about to expire after 30 days.
If the draft benefit request is not submitted within 30 days of initiation, USCIS ELIS
deletes the information. If submitted, information provided in the benefit request becomes
permanent and used according to the processes described in DHS/USCIS/PIA-042 Account and
Case Management (ELIS-2) PIA and DHS/USCIS/PIA-043 Automated Background Functions
(ELIS-3) PIA.

3.2

Does the project use technology to conduct electronic
searches, queries, or analyses in an electronic database to
discover or locate a predictive pattern or an anomaly? If so,
state how DHS plans to use such results.

No. During the Temporary Account and Draft Benefit Request process, USCIS ELIS

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 15

performs a simple query of USCIS ELIS accounts to ensure no existing USCIS ELIS accounts are
associated with an email address before a new account is created.

3.3

Are there other components with assigned roles and
responsibilities within the system?

No. There is no intra-departmental sharing of temporary account or draft benefit request
data.

3.4

Privacy Impact Analysis: Related to the Uses of
Information

Privacy Risk: There is a risk that information collected by USCIS ELIS may be used for
a purpose incompatible with the original purpose of collection.
Mitigation: The purpose of the collection of information under the DHS/USCIS-014 –
Electronic Immigration System-1 Temporary Accounts and Draft Benefit Requests System of
Records is to provide an Applicant with a temporary account so that he or she may submit a
benefit request through USCIS ELIS for the first time. All draft benefit request information is
collected and used to assist the Applicant or Representative when completing a benefit request.
In addition, the DHS/USCIS-014 – Electronic Immigration System-1 Temporary Accounts
and Draft Benefit Requests System of Records only permits the sharing of this information to
those parties needed to respond to a system breach and to contractors hired to maintain the
system. System administrators have technical access to the draft data, but may only access it for
system maintenance purposes. USCIS will keep audit logs to determine who accessed each part
of the system and when.
Privacy Risk: There is a risk that incomplete draft information collected during the
temporary account or draft benefit request process could be used to make an adverse
determination about an Applicant or Co-Applicant.
Mitigation: USCIS does not need to know the benefit request information until an
Applicant attests to the accuracy and completeness of the information and formally applies for a
USCIS benefit. USCIS ELIS segregates draft benefit request data from other data in USCIS
ELIS to prevent adjudicators or others from using information that has not been formally
submitted by the Applicant. While all data in the system, including temporary account and draft
benefit request data, is accessible by USCIS ELIS system administrators, these users may only
access the data for system maintenance and stability purposes, not to process or act upon any of
the information.
Privacy Risk: The security of an Applicant’s temporary USCIS ELIS account may be
breached by a third party.
Mitigation: All connections to USCIS ELIS are encrypted. Applicants receive
instructions about how to create an account with a strong password, and challenge questions or a
second-factor authentication method are used to mitigate the risk of a breach by a third party.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 16

USCIS instructs Applicants and Representatives to secure their account information to ensure
confidentiality. USCIS also notifies the Applicant or Representative that divulging confidential
information provided to USCIS within the USCIS ELIS account creation or benefit request
process to others creates a risk that benefit requests may be altered or that PII may be disclosed,
inadvertently or deliberately.
Privacy Risk: There is a risk that USCIS personnel who have access to the information
contained in USCIS ELIS will use the information in an unauthorized manner.
Mitigation: DHS Management Directive System (MD) Number: 11042, “Safeguarding
Sensitive But Unclassified (For Official Use Only) Information” (May 11, 2004), provides
guidance for the manner in which DHS employees and contractors must handle Sensitive But
Unclassified/For Official Use Only Information. Additionally, all DHS employees are required to
take annual computer security training, which addresses this issue.
USCIS ELIS also maintains Rules of Behavior which conform to DHS Sensitive Systems
Policy Directive 4300A - Rules of Behavior for employees who use DHS systems. Rules of
Behavior are part of a comprehensive program to provide complete information security. These
guidelines are established to hold users accountable for their actions and responsible for security.
OMB Circular A-130 Revised “Management of Federal Information Resource” requires that all
major applications and general support systems have Rules of Behavior. USCIS ELIS users are
required to read and sign the Rules of Behavior prior to receiving access to the system. A record
of those users who have signed the Rules of Behavior is maintained by the Information System
Security Officer, and disciplinary action can be taken for violating the Rules of Behavior. These
rules cover system access, passwords and other access control measures, data protection, use of
government office equipment, software, internet and e-mail use, incident reporting, and
accountability. Users acknowledge, by signing and dating the DHS Rules of Behavior, that
violating the system rules of behavior will involve potential disciplinary actions. Any person
who fails to comply with the rules of behavior is subject to penalties and sanctions, including:
verbal or written warning; removal of system access for a specific period of time; reassignment to
other duties; criminal or civil prosecution; or termination, depending on the severity of the
violation.

Section 4.0 Notice
4.1

How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain
why not.

USCIS ELIS provides Applicants and Representatives notice throughout the account
creation and benefit request process. Prior to the submission of any information to USCIS ELIS,
individuals are presented with a Privacy Act Statement, as required by Section (e)(3) of the
Privacy Act. The Privacy Act Statement notifies the individual about the authority to collect the
information requested, purposes, routine uses, and consequences of providing or declining to

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 17

provide the information to USCIS. Individuals are also provided general notice through the
publication of this PIA and information provided on www.uscis.gov. Further, DHS/USCIS
issued a SORN, DHS/USCIS-014 – Electronic Immigration System-1 Temporary Accounts and
Draft Benefit Requests System of Records (76 FR 70730, November 15, 2011) to cover the
collection, maintenance, and use of this information.
In addition, USCIS engages in public outreach efforts to educate potential users about
USCIS ELIS. This effort includes demonstrations of the system and opportunities for the public
to provide feedback about the system.

4.2

What opportunities are available for individuals to consent
to uses, decline to provide information, or opt out of the
project?

Providing information to USCIS is a voluntary act on the part of the Applicant seeking a
benefit through USCIS ELIS. Applicants are informed at the point of data collection that it is
within their legal rights to decline to provide the requested information. However, failure to
provide the requested information may result in the inability to create a temporary USCIS ELIS
account or to electronically draft and submit a benefit request. Declining to provide all of the
required information on a benefit request or to provide payment may result in USCIS declining to
accept the benefit request. If the Applicant or Representative does not submit the benefit request,
USCIS deletes it after 30 days and does not grant a benefit.

4.3

Privacy Impact Analysis: Related to Notice.

Privacy Risk: There is a risk that the Applicant may not be fully aware of how his or her
information will be used by USCIS.
Mitigation: Applicants are given notice through the publication DHS/USCIS-014 –
Electronic Immigration System-1 Temporary Accounts and Draft Benefit Requests System of
Records in the Federal Register and this PIA. Applicants are also given notice in the form of a
Privacy Act Statement that the information they provide is being collected to establish a unique
account, which entails checking for existing accounts associated with the provided email address.
Through statements in the SORN, this PIA, and the USCIS ELIS website, Applicants are
given notice that USCIS does not view their draft benefit request data or consider their eligibility
for the benefit they seek until they formally submit the benefit request. Applicants are also given
notice in the form of a Privacy Act Statement that the information they provide is being collected
to determine whether they are eligible for the requested benefit(s).
Privacy Risk: There is a risk that Co-Applicants may not be aware that an Applicant has
provided their information to USCIS.
Mitigation: Pursuant to 8 C.F.R 103.2(a)(3), Co-Applicants may not access, modify, or
participate in benefit requests submitted by the Applicant. USCIS relies on an Applicant who
lists a Co-Applicant on his or her benefit request to act with the consent of the Co-Applicant. For

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 18

example, a Co-Applicant is usually the Applicant’s spouse or child.

Section 5.0 Data Retention by the project
5.1

Explain how long and for what reason the information is
retained.

If a first-time Applicant does not begin drafting a benefit request within 30 days of
creating the temporary account, USCIS ELIS deletes the temporary account. If a first-time
Applicant begins drafting a benefit request within 30 days of creating the temporary account, he
or she has 30 days to submit the benefit request. This allows the Applicant to start, stop, and edit
the draft benefit request while gathering the information necessary to submit a completed benefit
request. If he or she does not submit the benefit request within 30 days of starting a draft benefit
request, USCIS ELIS deletes the temporary account and all draft benefit request data.
If an Applicant or Representative formally submits a benefit request within the 30-day
window, USCIS converts the temporary account to a permanent USCIS ELIS account and retains
the account and benefit request information according to the DHS/USCIS/PIA-042 Account and
Case Management (ELIS-2) PIA and DHS/USCIS/PIA-043 Automated Background Functions
(ELIS-3) PIA.

5.2

Privacy Impact Analysis: Related to Retention.

Privacy Risk: There is a risk that information will be retained longer than necessary.
Mitigation: In order to reduce the risk of mishandling temporary USCIS ELIS account
or draft benefit request data, the retention period is 30 days after initiation.
Privacy Risk: There is a risk that after an Applicant or Representative changes
information on a draft benefit request, the original data will be kept by USCIS.
Mitigation: USCIS only stores the last version of a draft benefit request.
Privacy Risk: There is a risk that USCIS could retain draft benefit request information
on tape backups after the application has been formally submitted or deleted.
Mitigation: USCIS does not retain temporary account or draft benefit request data on
backup tapes in the traditional sense. A real-time copy of this data is kept at a backup facility for
disaster recovery purposes, but it is deleted at the same time as the original data. Thus, when a
temporary USCIS ELIS account and draft benefit request are abandoned for 30 days, USCIS
deletes the data from both USCIS ELIS and the backup facility.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 19

Section 6.0 Information Sharing
6.1 Is information shared outside of DHS as part of the normal
agency operations? If so, identify the organization(s) and how the
information is accessed and how it is to be used.
No. USCIS does not share temporary account and draft benefit request information
outside of DHS.

6.2

Describe how the external sharing noted in 6.1 is compatible
with the SORN noted in 1.2.

As noted in the DHS/USCIS-014 – Electronic Immigration System-1 Temporary Accounts
and Draft Benefit Requests System of Records , USCIS does not share temporary USCIS ELIS
account or draft benefit request information externally.

6.3

Does the project place limitations on re-dissemination?

Yes. USCIS ELIS does not share temporary account or draft benefit request information
outside DHS.

6.4

Describe how the project maintains a record of any
disclosures outside of the Department.

USCIS ELIS does not disseminate temporary account and draft benefit request
information. Once the Applicant or Representative submits the benefit request, USCIS ELIS
uses, maintains, and shares the information according to the DHS/USCIS/PIA-042 Account and
Case Management (ELIS-2) PIA and DHS/USCIS/PIA-043 Automated Background Functions
(ELIS-3) PIA, which describes the procedures for records of disclosures.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk of potentially inappropriate or unauthorized sharing or use
of this information.
Mitigation: USCIS has minimized this risk by prohibiting the sharing of any
information outside of USCIS during the creation of a temporary USCIS ELIS account or during
the drafting of a benefit request. After an Applicant has successfully created a temporary USCIS
ELIS account and has begun drafting a benefit request, the risk of unauthorized information
sharing is mitigated by strict adherence to the DHS/USCIS-014 – Electronic Immigration System1 Temporary Accounts and Draft Benefit Requests System of Records (76 FR 70730, November
15, 2011). The SORN does not provide for any approved Routine Use (aside from investigating
system breaches or authorizing contractors to perform system maintenance) until the Applicant or
Representative formally submits the benefit request, authorizing USCIS to use that information.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 20

Section 7.0 Redress
7.1

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

The nature of the temporary USCIS ELIS account prevents an Applicant from editing his
or her email address until he or she submits the first benefit request. All other information may
be edited for 30 days before it is deleted. Once the Applicant has submitted his or her first benefit
request, the account is made permanent and the Applicant may edit the email address associated
with their USCIS ELIS account. If a Representative has drafted the benefit request, the Applicant
must review and sign the benefit request, either physically or electronically, before it may be
submitted. If the Applicant identifies errors, he or she may decline to sign the draft benefit
request, and the Representative may make the appropriate corrections.
Pursuant to 8 CFR 103.2(a)(3), Co-Applicants may not access, modify, or participate in
benefit requests submitted by the Applicant. However, Co-Applicants may create their own
USCIS ELIS accounts and submit their own benefit requests. If the Co-Applicant later requests a
benefit as an Applicant, USCIS ELIS merges the individual’s Applicant and Co-Applicant
accounts. See the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA for more
information.

7.2

What procedures are in place to allow the subject individual
to correct inaccurate or erroneous information?

As described above in Section 7.1, Applicants and Representatives may log in to USCIS
ELIS over a period of 30 days to view and edit draft benefit requests so that they may ensure the
information is accurate and complete. Once the benefit request has been submitted, it cannot be
modified through the Temporary Account and Draft Benefit Request process. Modification of
submitted information may only be done through the Account and Case Management process,
which begins after the Applicant or Representative has formally submitted a benefit request. See
the DHS/USCIS/PIA-042 Account and Case Management (ELIS-2) PIA for a detailed
explanation.
Because of the temporary nature of the temporary accounts and un-submitted draft
benefit requests, individuals cannot access these records under the Freedom of Information Act
(FOIA). However, if the benefit request is formally submitted, individuals may access their own
information by logging in to USCIS ELIS or submitting a request in writing to:
National Records Center
FOIA/PA Office
P.O. Box 648010
Lee’s Summit, MO 64064-8010
If an individual believes more than one component of DHS maintains Privacy Act
records concerning him or her, the individual may submit the request the component's FOIA

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 21

Officer,
whose
contact
information
can
be
found
at:
http://www.dhs.gov/xfoia/editorial_0579.shtm under “contacts,” or to the Chief Privacy Officer,
Department of Homeland Security, 245 Murray Drive, SW., Building 410, STOP-0550,
Washington, DC 20528.

7.3

How does the project notify individuals about the
procedures for correcting their information?

After successfully creating a temporary USCIS ELIS account, the USCIS ELIS displays a
notice to the Applicant reminding him or her to ensure the accuracy of all information prior to
submission.
When an Applicant or Representative logs in to USCIS ELIS, draft benefit requests are
immediately presented. If a benefit request is approaching the 30-day deadline, a notification is
sent to the Applicant or Representative as a reminder. Once the benefit request has been
submitted, the processes described in the DHS/USCIS/PIA-042 Account and Case Management
(ELIS-2) PIA are used to notify the Applicant or Representative. Otherwise, the Applicant or
Representative is notified through the instructions, tips, and help provided in USCIS ELIS, the
publication of the DHS/USCIS-014 – Electronic Immigration System-1 Temporary Accounts and Draft
Benefit Requests System of Records, and this PIA.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that inaccurate or erroneous information will be entered by
an Applicant during the creation of a temporary USCIS ELIS account or during the drafting of a
benefit request.
Mitigation: USCIS ELIS confirms that the email address provided by the Applicant is
not associated with an existing account, is a valid email address, and is accessible by the
Applicant. Using the email address, password, and second factor authentication process, an
Applicant may make corrections and/or deletions to any inaccurate or erroneous information
during the 30 day window after initiation of a benefit request. Prior to submission of a benefit
request, an Applicant and/or Representative must view a snapshot of the provided information,
verify its accuracy, and correct any errors before signing and submitting the benefit request.
Privacy Risk: An Applicant or Representative may mistakenly believe that he or she has
completed drafting a benefit request but has failed to formally submit it. In this situation, the
Applicant’s redress rights may be limited.
Mitigation: USCIS ELIS warns Applicants and Representatives before they draft a
benefit request that his or her benefit request will not be considered until the Applicant or
Representative receives a USCIS ELIS confirmation receipt number.
Applicants and
Representatives can check the status of their benefit requests within USCIS ELIS and will receive
confirmation of their submission through their preferred notification procedure (mail, email, or
SMS text message).

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 22

Privacy Risk: Co-Applicants do not have any redress rights.
Mitigation: Pursuant to 8 CFR 103.2(a)(3), Co-Applicants may not access, modify, or
participate in benefit requests submitted by the Applicant. However, if a Co-Applicant is about to
be denied a benefit, USCIS allows the Co-Applicant to contest the basis for the denial. Also, CoApplicants may create their own USCIS ELIS accounts and submit their own benefit requests. If
the Co-Applicant later requests a benefit as an Applicant, USCIS ELIS merges the individual’s
Applicant and Co-Applicant accounts, and provides the individual access to the data provided
about them as a Co-Applicant.

Section 8.0 Auditing and Accountability
8.1

How does the project ensure that the information is used in
accordance with stated practices in this PIA?

USCIS has built in technical safeguards that segregate draft application data from other
data in USCIS ELIS. These safeguards ensure that the data is only viewable and accessible to the
Applicant or Representative while in a draft stage. Limiting the retention of the data to 30 days
reduces the likelihood that USCIS and third parties will be able to access or abuse this data.
In accordance with National Institute of Standards and Technology (NIST) controls and
OMB requirements, USCIS staff and/or administrators of the USCIS ELIS conduct a selfassessment of privacy policies and security controls, at least annually, to determine the extent to
which policies and controls are implemented correctly, operating as intended, and producing the
desired outcome with respect to meeting the privacy and security requirements for the operating
environment.

8.2

Describe what privacy training is provided to users either
generally or specifically relevant to the project.

All internal USCIS ELIS users, whether federal employees or contractors, complete
annual privacy training to ensure they properly handle PII. DHS personnel, contractors, and
vendors with significant security responsibilities (e.g., Information System Security Officers and
system administrators) receive initial specialized training, and annual refresher training thereafter,
specific to their security and privacy responsibilities. Additionally, USCIS provides privacy
training specific to USCIS ELIS, as necessary. Staff who maintain USCIS ELIS also train
personnel in their incident response roles and responsibilities with respect to the USCIS solution,
as well as provide refresher training on an annual basis.
USCIS maintains training records, including name and position, type of training received,
and costs of training. USCIS requires IT security and privacy awareness training before
authorizing IT accounts.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 23

8.3

What procedures are in place to determine which users may
access the information and how does the project determine
who has access?

As USCIS ELIS develops, employees will have access to different views and content
based on their roles and access privileges. All USCIS ELIS employees will have their access
recorded along with their activities in USCIS ELIS. Once within USCIS ELIS, an employee’s
access will be restricted based on their role and profile. Each user’s view will be limited to the
data required to perform their job function (e.g., adjudicator, supervisor, or performance analyst ).
Only System Administrators have the capability to access draft benefit request data, as required to
ensure the stability and maintenance of the system.

Privacy Impact Assessment
U.S. Citizenship and Immigration Services
USCIS ELIS-1 Temporary Accounts and Draft Benefit Requests
Page 24

8.4

How does the project review and approve information
sharing agreements, MOUs, new uses of the information,
new access to the system by organizations within DHS and
outside?

USCIS does not share temporary USCIS ELIS account and draft benefit request
information. However, once an application has been formally submitted, USCIS ELIS shares
benefit request information according to the Routine Uses of the applicable SORNs and the
Privacy Act of 1974. The USCIS Office of Transformation Coordination - Program Management
Office, USCIS Office of Information Technology, USCIS Privacy Office and USCIS Office of
Chief Counsel will review all MOUs prior to approval of sharing USCIS ELIS information.
New uses of information and/or new access requests for the system by organizations
within DHS and outside agencies will be evaluated through the USCIS change control process,
including assessments of impact, and will be approved by the proper Program Authorities of this
process (e.g., USCIS Office of Transformation Coordination’s Change Control Board, USCIS
Privacy Office, USCIS Office of Information Technology, and DHS offices where applicable).

Responsible Officials
Donald Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
Department of Homeland Security

Approval Signature

[Original signed copy on file with the DHS Privacy Office]

Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security