Pia 003

Privacy Impact Assessment
for the

Integrated Digitization Document
Management Program (IDDMP)
DHS/USCIS/PIA-003(a)
September 24, 2013
Contact Point
Donald Hawkins
Privacy Officer
United States Citizenship and Immigration Services
(202) 272-8030
Reviewing Official
Jonathan R. Cantor
Acting Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

Privacy Impact Assessment
USCIS, IDDMP
Page 2

Abstract
The United States Citizenship and Immigration Services (USCIS) is republishing the previously
published Privacy Impact Assessment (PIA) for the Integrated Digitization Document Management
Program (IDDMP). IDDMP is the process of digitizing paper-based case files (A-Files and Receipt Files)
and storing them in the Enterprise Document Management System (EDMS). EDMS enables the A-File to
be shared more efficiently within the Department of Homeland Security (DHS) and with external
agencies. USCIS is updating and reissuing this PIA to discuss in greater detail the IDDMP process in
which information is ingested into EDMS.

Overview
The United States Citizenship and Immigration Services (USCIS), a component of the
Department of Homeland Security (DHS), is responsible for administering and processing applications
for all immigrant and nonimmigrant benefits. To support immigration benefit operations, USCIS
assembles a paper-based file, known as an Alien-File (A-File), which contains official immigration
records of aliens or persons who are not citizens or nationals of the United States (U.S.) This function
was previously the responsibility of the legacy Immigration and Naturalization Service (INS), which
began issuing each alien an Alien Registration number (A-Number) in 1940, and on April 1, 1944, began
using this number to create individual A-Files. A-Files contain all records of any active case of an alien
not yet naturalized, including records created as he or she passes through the U.S. immigration and
inspection process and, when applicable, records related to any law enforcement action against or
involving the alien.
Since the formation of DHS in 2003, the U.S. immigration system has been managed by the
following DHS components: 1) USCIS, which performs the immigration benefit adjudication process; 2)
Customs and Border Protection (CBP), which performs the border enforcement and inspection processes;
and 3) Immigration and Customs Enforcement (ICE), which performs the investigatory, deportation, and
immigration court functions. Although USCIS is the custodian of the A-File, all three components create
and use A-Files in the course of performing their mission requirements.
In addition to the management of A-Files by the DHS tri-components, the U.S. Department of
State (DoS) also plays an important role in providing necessary immigration information to certain AFiles. DoS issues immigrant visas to individuals wishing to live permanently in the U.S.1 In general, to
apply for an immigrant visa, a foreign citizen must be sponsored by a U.S. citizen relative, U.S. Legal
Permanent Resident (LPR), or by a prospective employer, and must be the beneficiary of an approved
USCIS petition. Once USCIS approves the petition, it assigns the immigrant visa petition a Priority Date
and sends the petition to the DoS National Visa Center (NVC). DoS NVC then manages the case and
provides further instructions to the applicants, and collects and reviews required documents and evidence.
After DoS processes the visa, the visa recipient must indicate that he or she intends to adjust his
or her status with USCIS. If he or she would like to pursue becoming an LPR, DoS sends USCIS all of
1

A citizen of a foreign country who seeks to enter the U.S. generally must first obtain a U.S. visa, which is placed in
the traveler’s passport, a travel document issued by the traveler’s country of citizenship.

Privacy Impact Assessment
USCIS, IDDMP
Page 3

the applicant information it collected as part of the visa process to be included in the A-File.2 USCIS uses
this information to determine if the applicant is eligible to adjust to a permanent resident.
Paper A-Files are currently under the control of the USCIS National Records Center (NRC) and
the National Archives and Records Administration’s (NARA) Kansas City Federal Record Center
(KCFRC). However, USCIS, CBP, and ICE employees, who are stationed both domestically and
internationally, require access to the A-File regularly to assist in adjudicating benefits, investigating
immigration violations, and enforcing border protections. Because the A-File is inherently paper-based,
sharing the physical file is expensive, prone to handling errors, and difficult to share within and across
DHS components.
USCIS developed the Integrated Digitization Document Management Program (IDDMP) to
manage the digitization of files and to provide electronic access to case files, including A-Files and
Receipt Files, using the Enterprise Document Management System (EDMS).3 IDDMP manages the
process of scanning case files, which occurs at numerous capture facilities and including (1) Scan on
Demand (SODA) at the NRC; (2) the USCIS Lockboxes; (3) the Records Digitization Facility (RDF); and
(4) DoS. These capture facilities scan relevant case files and ingest them into EDMS through system
interfaces. IDDMP also covers EDMS’s ability to store, update, and access the electronic case file. Once
scanned, the electronic version of the file becomes the official A-File and can be accessed by the tricomponents using EDMS.
Enterprise Document Management System (EDMS)
EDMS is a web-based system that allows authorized users to view and search electronic copies of
the paper-based case files: A-Files and Receipt Files. The tri-components require access to the
information contained in these case files to learn the status of individuals, including permanent residents,
naturalized citizens, border crossers, apprehended aliens, legalized aliens, aliens issued employment
authorization, and other individuals of interest in order to successfully complete their job functions.
EDMS permits quick and simultaneous access to case files 24 hours a day, 7 days a week.
Prior to the implementation of EDMS, USCIS manually provided case files to the tri-components
in need of the file. If one of the tri-components requested a file, USCIS NRC staff queried the National
File Tracking System (NFTS)4 or the Central Index System (CIS)5 for the physical location of the A-file,
and would mail, fax, or email the case file to the requestor. Because this is a labor-intensive and time
consuming process, USCIS sought out a more efficient means of sharing the file.
To alleviate this problem, USCIS developed EDMS to facilitate efficient information sharing.
Tri-components requiring access to case files can now access the electronic file directly through EDMS,
2

DoS may send the application, Affidavit of Support forms from sponsors, supplementary evidence, adjudicator
notes, and any other information collected as part of the visa issuing process.
3
EDMS also contains Receipt Files, which are files of immigrant and nonimmigrant benefit applications that USCIS
receives. While the Receipt Files and supporting documentation are eventually consolidated into an A-File, EDMS
allows users to view the immigrant and nonimmigrant applications electronically before receiving the official paperbased application. This allows USCIS adjudicators to begin processing cases in a quick and efficient manner.
4
For a comprehensive explanation of NFTS, please refer to the DHS/USCIS/NFTS-032 PIA at
www.dhs.gov/privacy.
5
For a comprehensive explanation of CIS, please refer to the DHS/USCIS/CIS-009 PIA at www.dhs.gov/privacy.

Privacy Impact Assessment
USCIS, IDDMP
Page 4

which eliminates the paper-based process and reliance on physical case files. Additionally, the
digitization of these files reduces the time for delivery from days to seconds and allows for multiple
people to view the information at the same time.
There are two separate search functions in EDMS that users can search to locate either an A-File
or Receipt File. Users can search EDMS to locate A-files and Receipt files using specific search criteria
that allow the users to view the images in electronic format. Users can search A-Files in EDMS by either
populating the A-Number, First Name, Middle Name, Last Name, Aliases, Date of Birth (DOB), Country
of Birth (COB), Sex, Federal Employer Identification Number (FEIN), and Company Name fields. Users
can search Receipt files in the same manner by using the Receipt Number that is assigned to the specific
application, First Name, Last Name, A-Number, DOB, Accept/Reject Status, and/or Form Type.
The search capabilities within EDMS allow users to discover information that is buried deep
within the physical A-File in a reduced time period through the use of metadata. Metadata are “tags”
embedded into each document within the electronic case file for indexing and searching the digitized
files. Metadata saved with every digitized A-File includes:







First Name
Last Name
A-Number
DOB
COB
Receipt Number

Although users cannot modify the digitized images within the file, EDMS enables users to locate
information within the case file, add comments, modify documents contained within an A-File (dependent
on a user role), and add additional documents to the file, through a process known as interfiling.
Furthermore, there are three digitization notification interfaces that allow EDMS to update the
location in each system. EDMS provides real-time reporting via the EDMS web portal and deployed web
services to track the status and errors related to ingestion. This ensures that the information in EDMS is
accurate, complete, and up-to-date.
While only the tri-components have direct access to EDMS, contents in the digitized A-File are
authorized to be shared with various external agencies pursuant to the routine uses outlined in the
Alien File, Index, and National File Tracking System of Records Notice (SORN).6 For example, when
there is a valid business need, the A-File can be provided to federal, state, tribal, local, or foreign
government agencies or organizations, or international organizations, responsible for providing
benefits, investigating or prosecuting violations of civil or criminal laws, or protecting our national
security.

6

The DHS/USCIS-001 - Alien File, Index, and National File Tracking System of Records Notice (June 13, 2011,
76 FR 34233) is available at www.dhs.gov/privacy.

Privacy Impact Assessment
USCIS, IDDMP
Page 5

Case File Digitization Processes
IDDMP manages the scanning, receiving, storing, updating, and accessing of digital case files
into EDMS. There are four processes that allow case files to be digitized and ingested into EDMS through
system interfaces, including: (1) SODA; (2) the USCIS Lockbox; (3) the RDF; and (4) DoS. Tricomponent employees can request that case files be digitized directly within EDMS or, if applicable, by
contacting the capture facility in which the file is located. Once the employee sends the digitization
request through EDMS, EDMS will locate the facility that maintains the file to begin the digitization
processes. Each capture facility has an interface with EDMS to complete the automated ingestion of
information into EDMS.
Scan on Demand (SODA)
SODA refers to the process of digitizing a paper-based A-file and making it available
electronically upon receiving a request from a tri-component. The need to digitize an A-file is typically
triggered by a submission by a tri-component that needs information contained in the file to assist in
adjudicating a benefit application, initiating an enforcement action, or responding to a Freedom of
Information Act (FOIA) or Privacy Act (PA) request. After USCIS receives a request, a USCIS NRC or
NARA KCFRC employee will physically pull the requested paper files, digitize them, and make them
available for the tri-components electronically in EDMS.
USCIS performs SODA for files located at the NRC or the NARA KCFRC. The NRC is the
agency’s primary record keeping facility that houses millions of immigration records in A-Files. NARA
maintains USCIS records deposited with the National Archives of the United States at the NARA
KCFRC.
The SODA digitization process involves three fundamental steps: (1) requesting a physical
record; (2) producing the digitized records; and (3) delivering the digitized record.
Step 1: Requesting a record:
The requesting tri-component will submit a request for a file to be digitized within EDMS or by
contacting the USCIS NRC Information Liaison Division (ILD) by email or phone; a person from the
requesting component will generally provide the NRC with an A-Number or other identifying
combination of personally identifiable information (PII), such as a name, country of birth, and date of
birth of the individual whose A-file it wants digitized. ILD staff will log the request, including the ANumber and the requesting component personnel’s contact information, into the SODA database.
ILD staff then use NFTS or CIS, the systems that track the location of A-files, to locate the
physical paper A-file and include the location of the file in the SODA database. Once the ILD employee
inputs the request into the SODA database, it is sent to another NRC employee for manual retrieval of the
file.

Privacy Impact Assessment
USCIS, IDDMP
Page 6

Step 2: Producing the digitized record:
Once the A-file is located, the NRC staff will physically pull the file from the facility and convert
the paper A-File into an electronic record.7 NRC ILD staff use a scanner to scan files and then convert
them to a format compatible with EDMS. NRC Quality Assurance (QA) staff reviews the digitized files
to ensure they are identical and consistent with the paper file.
After the QA review, NRC staff uploads the scanned A-files into the capture facility to notify
EDMS that the files are available. Once the notification has been received, EDMS retrieves the files via
web services through the ingestion process. Once the NRC ingests the file into EDMS, all files are deleted
from the scanner.
Step 3: Delivery of the digitized record:
Requests for files to be digitized are generally responded to within 15 days, depending on where
the file is located. Once USCIS digitizes the file, it becomes the official immigration record.8 Once
EDMS ingests the A-File, it is searchable by the tri-component requester and any EDMS user.
The SODA database, which does not have a direct connection to EDMS, facilitates the
digitization process, tracks pending requests, and compiles weekly, monthly, and yearly statistics related
to the SODA process and administrative and system errors. NRC employees also use the database to
manually record errors found during the government QA process and to track the correction of those
errors.
USCIS Lockbox
In addition to A-Files, digitized Receipt Files from the USCIS Lockbox facility (Lockbox) that
are scanned for initial intake processing are also ingested into EDMS.9 Upon completion of a USCIS
benefit application, USCIS instructs applicants to mail the form and any accompanying documentation to
the appropriate Lockbox facility, which is found on the USCIS website and appropriate form. The
Lockbox manages the intake of USCIS applications, petitions, and requests and the collection of
associated fees submitted directly by mail. It provides the mechanisms to capture information
electronically from USCIS applications, petitions, and requests; to deposit associated fees; to forward the

7

In some cases, the requestor will only need one piece of information located in the A-File. If this is the case, ILD
will pull that piece of information from the file and send only that information to the requestor by an encrypted
email or secure fax.
8
The electronic copy will become the official record pursuant to USCIS policy “Use of Digitized A-Files,” dated
March 28, 2008.
9
The Lockbox facilities are operated by a financial agent authorized by the Department of Treasury. The financial
agent is also responsible for preparing the files in accordance with USCIS guidance and sending the files to the next
processing site. The financial agent does not approve or deny petitions/applications/requests received. USCIS has a
business arrangement with the Department of the Treasury to allow Bank One, N.A. to serve as the USCIS financial
agent. Bank One, N.A. provides USCIS lockbox imaging, check collection, and initial processing services. For more
information regarding the Lockbox services provided by the Department of Treasury and appropriate financial
agents, please see the Department of Treasury Electronic Check Processing PIA, available at
http://www.fms.treas.gov/pia/ECP_PIA.pdf and the accompanying system of records notice, Treasury/FMS.017 Collections Records -Treasury/Financial Management Service, May 15, 2009 (74 FR 23019) available at
http://www.treasury.gov/FOIA/Pages/fmspa.aspx.

Privacy Impact Assessment
USCIS, IDDMP
Page 7

information to USCIS systems via an interface; and to generate receipt and rejection notices to
individuals.
The Lockbox personnel review newly received filings to ensure they are properly filed. The
Lockbox verifies the completion of the following items: basic biographical information, signature on the
form, jurisdiction of the submitted form, correct fee, and basic eligibility of the individual. Once Lockbox
personnel review the filings for accuracy, they convert the applications to electronic images called
Receipt Files and upload them into EDMS.
The digitized Receipt Files are not considered the official USCIS record of the Receipt File and
displays a watermark stating “COPY” on the electronic copy of the receipt file. The paper file remains the
official record for the Agency. However, the Receipt Files are converted into an electronic format to
research customer inquiries regarding accepted and rejected applications processed by the Lockbox, and
to begin initial application review before the hardcopy is received from the Service Center.
The Lockbox provides document scanning and metadata capture to integrate with EDMS. Once
the Receipt file is ingested into EDMS, it is searchable by any EDMS user. The Lockbox is searchable by
receipt number because those temporary records are not yet A-Files. The Receipt File is eventually added
to the A-file. A-Files in EDMS are searchable by A-Number, Name, Date of Birth, and Country of Birth.
Once an A-number is assigned and the file is ingested into EDMS, the file become searchable by Anumber and by the other metadata elements listed above.
Records Digitization Facility (RDF)
RDF provides physical and electronic records management, document scanning, metadata
capture, and creation of information to integrate A-File images into EDMS. RDF is dedicated to
providing its customers with timely access to complete and accurate information contained in the USCIS
digitized files. Oversight of the RDF falls within the purview of the USCIS Headquarters Records
Division, Program Management Office. The RDF process of ingesting files into EDMS is similar to
SODA, except the files are not ingested upon request. Instead, the RDF is a multi-year plan to digitize
approximately 1 million files per year and more than 70 million paper files over the course of several
years. RDF staff use a scanner to scan files and then convert them to a format compatible with EDMS.
RDF QA staff review the digitized files to ensure they are identical and consistent with the paper file.
After the QA review, RDF staff upload the scanned A-files into the capture facility to notify
EDMS that the files are available. EDMS then retrieves the files via web services through the ingestion
process once the notification has been received. Once the RDF ingests the file into EDMS, all files are
deleted from the capture facility.
DoS Immigrant Visa Files
Previously, DoS shared this information with USCIS by sending USCIS the hardcopy forms and
supplementary evidence. USCIS then stored this information in the applicant’s paper A-File. As
previously described, the sharing of paper-based A-Files is a labor-intensive and timely process.
Digitizing files and storing them in a centralized system alleviates this process and allows USCIS to share
information more efficiently.

Privacy Impact Assessment
USCIS, IDDMP
Page 8

DoS has agreed to create an electronic file of all the files sent back to USCIS, for eventual
ingestion into EDMS. DoS has provided a server to USCIS containing a backlog of image files from
USCIS applications and supporting materials of individuals on the DoS waiting list for a visa. Depending
on the type of visa an individual is applying for, (e.g., immediate relative/family based, employment
based and/or special immigrant) there may be a numerical limit of visas granted each year, and wait times
may be involved. Wait times can vary, are dependent on the applicant’s country of citizenship, and can be
very lengthy. Visa processing will not occur until the NVC contacts the applicant and tells him or her that
the wait time is complete.
Once DoS approves the applicant’s visa and the applicant determines he or she would like to
adjust his or her status with USCIS, USCIS will assign the individual an A-number. At this point, USCIS
will retrieve the applicant’s information from the server and ingest the information into EDMS. No
information will be ingested into EDMS until the applicant is assigned an A-number. If the visa is denied,
or the applicant does not contact USCIS to adjust his or her status, the information will remain on the
server. The information contained on the servers cannot be retrieved or accessed by anyone other than the
server administrators. Once the individual is assigned an A-Number and his or her information is put into
EDMS, the information will be accessible by all EDMS users.
The above section describes all of the processes for ways in which information can be ingested
into EDMS for efficient sharing throughout the DHS tri-components. USCIS is republishing this PIA
because the previous PIA did not distinguish the different processes and sources for how information is
ingested into EDMS. By reissuing the PIA, we hope to fully address the privacy issues associated with
IDDMP and show each piece of the process. If additional process or users of EDMS are added in the
future, USCIS will update this PIA.

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 specific legal authority for this collection of information is Section 290(a) of the Immigration
and Nationality Act. Additionally, per Office of Management and Budget (OMB) Memorandum M-1218, “Managing Government Records Directive,” by 2019, all permanent electronic records in Federal
agencies will be managed electronically to the fullest extent possible for eventual transfer and
accessioning by NARA in an electronic format.10

1.2

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

The SORN that covers this collection of information is the Alien File, Index, and National File
Tracking SORN, June 13, 2011, 76 FR 34233.

10

The OMB Directive can be found at www.whitehouse.gov/omb.

Privacy Impact Assessment
USCIS, IDDMP
Page 9

1.3

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

EDMS was approved for operation on July 30, 2012, for a period of 18 months. The Authority to
Operate (ATO) is set to expire on January 31, 2014. The EDMS Security Plan was completed in March
2012.

1.4

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

NARA approved the EDMS N1-566-08-17 retention schedule. Additionally, the files sent to
USCIS by DoS are covered by the N1-566-12-03 retention schedule. USCIS retains A-Files and Receipt
Files in accordance with N1-566-08-11 and N1-85-96-01, respectively. N1-GRS-95-2 item 1c, governs
the SODA Database, which allows records to be deleted/destroyed when no longer needed for
administrative, legal, audit, or other operational purposes.

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.

IDDMP does not collect information directly from an individual and there are no forms
associated with this collection. The IDDMP maintains data from USCIS applications and petitions that
are covered by the PRA.

Section 2.0 Characterization of the Information
The following questions are intended to define the scope of the information requested and/or collected, as
well as reasons for its collection.

2.1

Identify the information the project collects, uses, disseminates, or
maintains.

A-File
IDDMP does not collect information not already collected through an existing process. IDDMP
digitizes hard copy A-Files so they may be shared more efficiently throughout DHS in support of benefit
application, enforcement action, or receipt of a FOIA/PA request.
The A-File contains information including, but not limited to:


First, Middle, and Last Name;



Alias(es);



Sex;



Address;



Telephone Number;

Privacy Impact Assessment
USCIS, IDDMP
Page 10



Social Security Number (SSN);



A-Number;



Passport Number;



DOB;



COB;



Country of Citizenship (COC);



Vital documents (e.g., birth certificates, passports, marriage certificates);



Biometric information (e.g., photographs, fingerprints);



Enforcement supporting documents (e.g., rap sheets); and



Other documents (e.g., naturalization certificates; tax returns; labor certifications;
correspondence; court dispositions; interview notes).

A-Files sometimes contain media that cannot be scanned, such as videotapes, audiotapes, and
CDs. The contents of such media will not be included in the digitized A-File, but the digitized A-File will
note its presence in the physical file.
Receipt File
The digitized Receipt File contains but is not limited to:


First and Last Name;



Alias(es);



Sex;



Address;



Telephone Number;



SSN;



A-Number;



Passport Number;



DOB;



COB;



COC; and



Any other information collected on the associated form.

SODA Database
The SODA database collects and stores the following information:

Privacy Impact Assessment
USCIS, IDDMP
Page 11



Employee/Requestor Name;



ILD Employee User ID;



Name of requesting agency;



A-Number; and



File location.

The metadata saved in EDMS with every digitized A-File includes:


A-Number;



First Name;



Last Name;



DOB;



COB; and



Receipt Number.

2.2

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

IDDMP does not collect data directly from an individual. The information contained in EDMS is
generally collected from an individual or representative seeking an immigration benefit or has some
encounter with the U.S. immigration system. The employee data contained in the SODA database is
collected directly from the DHS employee requesting the 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.

IDDMP does not collect information from commercial or publicly available data sources.

2.4

Discuss how accuracy of the data is ensured.

The accuracy of the data in EDMS is dependent upon the accuracy of the information in the
paper A-File and/or Receipt File. USCIS collects information contained in these files directly from the
individual or his or her representative. The A-File may also contain information that was input into the
file from tri-components or DoS during the course of providing benefits, investigating or prosecuting
violations, or protecting our nation.
Additionally, QA personnel perform extensive quality monitoring and assurance reviews
throughout the digitization process to ensure that the paper case files are scanned into legible and
accurately identified digitized files. Pages are checked to ensure that they are fully rendered; properly
aligned and ordered; free of distortions; and named correctly. Metadata entered at scanning operations
undergoes similarly rigid quality control checks. QA personnel will identify, review, correct, and log
inaccuracies to prevent recurrence.

Privacy Impact Assessment
USCIS, IDDMP
Page 12

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: The information contained in the case file may be inaccurate or incomplete.
Mitigation: The digitized file in EDMS may not include all material that exists for the paper case
files. If there is material within the A-File that cannot be digitized, i.e., video tapes, USCIS employees
will annotate in EDMS that one or more of documents in the original could not be scanned. USCIS
creates Temporary Files (T-File) to store permanent documents, when the original A-file is not available.
USCIS employees conduct searches in NFTS to determine if there are existing T-Files available. Lastly,
if errors are found in a digitized case file, the facility that digitized the file receives notice and the facility
employees review the electronic and physical file to correct the error. Furthermore, QA personnel perform
quality monitoring and assurance reviews throughout the digitization process and can identify, review,
correct, and log inaccuracies to prevent recurrence.

Section 3.0 Uses of the Information
The following questions require a clear description of the project’s use of information.

3.1

Describe how and why the project uses the information.

The uses of the information contained in EDMS are the same as the uses for the paper A-file and
Receipt File. The information is used for immigration benefits processing, law enforcement, and
protection of national security. Specific uses of these case files are to:


Confirm identity using dates of birth, photos, or other biographic or biometric information;



Confirm relationships using information found in birth, marriage, divorce, and/or adoption
certificates;



Confirm law enforcement actions using investigation reports, rap sheets, etc.;



Confirm previous immigration benefit processing, including both approvals and denials; and



Research customer inquiries and begin initial application review.

Storing case file information electronically in EDMS allows DHS, in the standard course of its
immigration-related business to: access the files more rapidly and efficiently, concurrently and
collaboratively use the files, and mitigate the risk of losing the paper-based files. EDMS eliminates the
inefficiencies associated with paper records, such as slow, resource-intensive shipping, high risk of loss,
and deterioration over time.

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.

IDDMP does not use technology to conduct electronic search, queries, or analyses to discover or
locate a predictive pattern or an anomaly.

Privacy Impact Assessment
USCIS, IDDMP
Page 13

3.3

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

The A-File, on paper or as digitized as part of IDDMP, is the record that contains all transactions
involving an individual as he or she passes through the U.S. immigration and inspection process, and
chronicles interactions with the U.S. Government. These functions have been divided among USCIS,
CBP, and ICE. Although USCIS is the custodian of the A-File, all three components create and use AFiles.
Once an A-File is digitized, information is accessible by all three components so that they may
perform their respective mission requirements. Information contained within the A-File may also be
shared with other components within DHS responsible for law enforcement activities and protection of
national security. In addition, access may be granted to the DHS Office of the Inspector General,
primarily for the purpose of conducting internal investigations and evaluations of DHS employees
conduct in the performance of their duties. Information is also shared in order to support associated
management reporting, planning and analysis, or other administrative uses that require access to the
information contained in the A-File.

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: Individuals who have legitimate access to PII could exceed their authority and use
the data for unofficial purposes.
Mitigation: USCIS strictly manages access controls and policies; auditing; and other physical,
technical, and administrative controls. USCIS limits the use and access of all data to purposes for which
it was collected. Only employees who need access to the A-File to perform their official duties are
granted access to EDMS. System users must complete mandatory Computer Security Awareness training,
Privacy training, and EDMS training. USCIS employees who take requests to digitize case files and who
digitize the files themselves have additional training on the process. All contractors must sign nondisclosure agreements. Data must always be securely transferred. For example, if EDMS data is
transferred on portable media or via email to authorized DHS employees, National Institute of Standards
and Technology (NIST)-approved encryption is used to ensure that data is not tampered with en route and
to prevent unauthorized personnel from viewing it.

Section 4.0 Notice
The following questions seek information about the project’s notice to the individual about the information
collected, the right to consent to uses of said information, and the right to decline to provide information.

4.1

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

IDDMP does not collect information directly from an individual. Instead, it scans paper-based
information originally provided to DHS by an applicant and stores the digitized A-Files in EDMS. All
individuals applying for a benefit are presented with a Privacy Act Statement that informs the individuals
of the purpose and authority for collection, routine uses of the information, and if the submission of

Privacy Impact Assessment
USCIS, IDDMP
Page 14

information is voluntary or mandatory. Individuals also receive general notice through the publication of
this PIA and the Alien File, Index, and National File Tracking System of Records Notice (SORN), June
13, 2011, 76 FR 34233.

4.2

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

IDDMP does not collect information directly from an individual. Information is collected by
various means and stored in EDMS as a digitized version of the paper A-File. Applicants who seek
USCIS benefits receive a Privacy Act Statement, which details the authority and uses of information.
When submitting the application, the applicant certifies and authorizes the release of any information to
appropriate agencies in accordance with the approved Routine Uses outlined in the applicable SORN.
USCIS informs the applicant at the point of data collection (generally on the form itself) that it is within
his or her rights to decline to provide the required information; however, it will result in the denial of the
benefit request.

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk of insufficient notice describing the purpose, use, and effects on the
requestor for failing to provide information.
Mitigation: USCIS mitigates this risk by providing notice to the individual prior to the collection
of information through the inclusion of a Privacy Act Statement on each form, the publication of this PIA,
and other relevant PIAs such as NFTS and CIS, on www.dhs.gov/privacy, and the publication of the AFile SORN in the Federal Register.

Section 5.0 Data Retention by the project
The following questions are intended to outline how long the project retains the information after the initial
collection.

5.1

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

The A-File is the record that contains all transactions involving an individual as he or she passes
through the U.S. immigration and inspection process. A-File records are permanent records in both
electronic and paper form. USCIS transfers A-Files to the custody of NARA 100 years after the
individual's date of birth.11 When USCIS digitizes a paper A-File, the digitized A-File maintained in
EDMS becomes the official record and maintains the same retention schedule as the original paper AFile. Once USCIS digitizes the files, it sends the paper-based files to NARA or the KCFRC.
Contrary to the digitized A-File, digitized Receipt Files are copies and not the official Agency
record of the Receipt File. The paper file remains as the official record for the Agency.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk that USCIS may retain information longer than is necessary to
approve or deny the benefit sought.
11

Newly-eligible files are transferred to the KCFRC every five years.

Privacy Impact Assessment
USCIS, IDDMP
Page 15

Mitigation: USCIS retains data beyond the approval or denial of a benefit in order to ensure the
information is available for several purposes, including future immigration status verification, evaluating
subsequent benefits sought by an applicant, and for litigation. The digitized A-File serve the same
purpose as the paper-based A-File, which NARA has determined to be of permanent historical value.
When information is no longer necessary, USCIS retires the records according to the retention schedules
listed in section 1.4 of this PIA.

Section 6.0 Information Sharing
The following questions are intended to describe the scope of the project information sharing external to
the Department. External sharing encompasses sharing with other federal, state and local government, and private
sector entities.

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.

Upon request, copies of a digitized A-File or certain documents within an A-File can be made
available to external agencies that do not currently have access to EDMS but have a valid need for the
immigration record. Encrypted PDF images from EDMS can be exported to CD for distribution through
postal mail or, alternatively, digitized A-File documents can be compressed and sent via e-mail as an
encrypted attachment. In special circumstances, such as national security events, the original physical AFile might be requested. If the need for the original physical A-File is valid, the paper file will be pulled
from retired status and sent to the requesting agency. The digitized version of the A-File will no longer
be available in EDMS in such instances.
Information in the digitized A-File may be shared with external organizations for the purpose of
providing benefits, law enforcement, or other uses consistent with the routine uses described in Alien File,
Index, and National File Tracking System of SORN, June 13, 2011, 76 FR 34233. Furthermore,
information may be shared with Department of Justice to assist in the development of agency’s legal
and/or policy position and Department of State in processing of petitions or applications for benefit under
the Immigration Nationality Act. If external agencies receive direct access to EDMS in the future, USCIS
will update this PIA.

6.2

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

USCIS only shares information outside of DHS as permitted under the Routine Uses outlined in
the Alien File, Index, and National File Tracking System of SORN, June 13, 2011, 76 FR 34233 SORN.

6.3

Does the project place limitations on re-dissemination?

Prior to disclosing any information to an external agency, DHS must have a Memorandum of
Understanding (MOU) in place with the partner agency fully outlining responsibilities of the parties,
security standards, and limits of use of the information, including re-dissemination. Methods and controls
over dissemination of information are coordinated between DHS the partner agency, prior to information
sharing. Depending on the context of other sharing, DHS may place additional controls on the re-

Privacy Impact Assessment
USCIS, IDDMP
Page 16

dissemination of the information.

6.4

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

Pursuant to 5 U.S.C. 552a(b) of the Privacy Act, all or a portion of the records or information
contained in this system may be disclosed outside DHS as a routine use pursuant to 5 U.S.C. 552a(b)(3).
For any external sharing, USCIS requires a representative from the outside agency to establish,
in writing, what specific information it needs about particular individuals and ensures that it is consistent
with the Routine Uses listed in the SORN. This is process is begins when the requesting agency
completes the G-658 Record of Information Disclosure (Privacy Act). This form is used to record the
reason for each disclosure and is maintained in the Subject’s A-File or maintained in such a way that it
can be easily retrieved when requested.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a privacy risk that USCIS may share data outside of DHS for purposes
that are not in accordance with the stated purpose and use of the original collection.
Mitigation: USCIS is careful to only share data with external agencies that have a need-to-know
and will use the information in a way that is compatible with the original purpose for collection described
in the A-File SORN. All external sharing arrangements are reviewed prior to the sharing of information
to ensure such uses are consistent with existing published routine uses in the applicable SORNs and/or
performed with the consent of the individual whose information is being shared. The Privacy Act
Statement included on USCIS Forms notifies the individual that USCIS may provide information from
the form to other government agencies. As required by DHS procedures and policies, all current external
sharing arrangements are consistent with the original purpose for which the information was collected.

Section 7.0 Redress
The following questions seek information about processes in place for individuals to seek redress, which
may include access to records about themselves, ensuring the accuracy of the information collected about them,
and/or filing complaints.

7.1

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

An individual may gain access to his or her USCIS records by filing a FOIA/PA request. Any
individual seeking access to his or her USCIS record may submit the aforementioned requests to
following address:
National Records Center
Freedom of Information Act/Privacy Act Program
P. O. Box 648010
Lee’s Summit, MO 64064-8010

Privacy Impact Assessment
USCIS, IDDMP
Page 17

The information requested may, however, be exempt from disclosure under the Privacy Act
because sometimes files contain law enforcement sensitive information and the release of could possibly
compromise ongoing criminal investigations. Further information for Privacy Act and FOIA requests for
USCIS records can also be found at http://www.uscis.gov.

7.2

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

USCIS treats all requests for amendment of information in a system of records as Privacy Act
amendment requests. Individuals may direct all requests to contest or amend information to the FOIA/PA
Office at USCIS at the address listed above. They must state clearly and concisely in the redress request
the information being contested, the reason for contesting it, and the proposed amendment thereof.

7.3

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

The procedures for individuals to amend their information are outlined in this PIA and Alien File,
Index, and National File Tracking SORN, June 13, 2011, 76 FR 34233.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a privacy risk that an individual’s opportunity for redress may be limited
by a Privacy Act exemption.
Mitigation: Individuals are given numerous opportunities during and after the completion of the
application process to correct information they have provided and to respond to information received
from other sources.

Section 8.0 Auditing and Accountability
The following questions are intended to describe technical and policy based safeguards and security
measures.

8.1

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

DHS security specifications require USCIS to maintain audit logs that document the activity of
each user in order to reduce the possibility of misuse and inappropriate dissemination of information. In
accordance with DHS security guidelines, USCIS systems use auditing capabilities that log user activity.
All user actions are tracked via audit logs to identify audit information by user identification, network
terminal identification, date, time, and data accessed. All USCIS systems employ auditing measures and
technical safeguards to prevent the misuse of data. USCIS systems have internal audits separate from the
domain security audits; therefore, a double layer of audit trails exists. Furthermore, each employee is
required to undergo annual security awareness training that addresses his or her duties and responsibilities
to protect the data.

Privacy Impact Assessment
USCIS, IDDMP
Page 18

8.2

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

USCIS provides annual privacy and security awareness training to all employees and contractors.
The Culture of Privacy Awareness training addresses appropriate privacy concerns, including Privacy Act
obligations. The Computer Security Awareness training examines appropriate technical, physical,
personnel, and administrative controls that safeguard information. Lastly, all users are required to
complete EDMS training prior to being granted access to the system.

8.3

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

EDMS has three types of users: general users, records administrators, and system administrators.
The permissions available at each level are outlined below. The user’s type will be identified at login,
authenticated through the DHS Active Directory instance, and the user will be assigned the correct access
rights.




General users have the ability to perform A-Number, metadata, and full-text searches, and view
documents.
Records administrators have the ability to view the documents for A-Files, can edit the metadata
for A-Files and their associated documents, and view reports on auditing and ingestion.
System administrators have the ability to view the metadata and documents for A-Files and can
delete them.

Functions
Logging In
A-Number / Account / Receipt File
Number Search
Expanded Search
Search Results
Search within an A-File
View/Print A-File Documents
(Watermarked)
View A-File Documents (NonWatermarked)
Print A-File Documents (NonWatermarked)
View/Print Account Documents
(Non- watermarked)
Export A-Files
Create Certified Printed copy of an
A-File
Edit Comments

General Users
X
X
X
X
X
X

X

Records Admin
X
X

System Admin
X
X

X
X
X
X

X
X
X
X

X

X

X

X

X

X

X

X

X

X
X

Privacy Impact Assessment
USCIS, IDDMP
Page 19

Delete Comments

X

Delete Documents

X

Delete A-Files

X

Edit Receipt File Retention Period
(Apply/Remove Hold)
Add descriptive text to
A-File documents

X

X

X

X

X

USCIS deploys role-based access controls and enforces a separation of duties throughout the lifecycle of
the electronic A-File. Access is limited to only those persons who have a need-to-know in order to
perform their duties. This need-to-know is determined by the respective responsibilities of the employee.

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 has formal review and approval process in place for new sharing agreements. Any new
use of information and/or new access requests for USCIS systems must go through the USCIS change
control process and must be approved by the proper authorities prior to sharing information within and
outside of DHS.

Responsible Officials
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services

Approval Signature
Original signed copy on file with the DHS Privacy Office

________________________________
Jonathan R. Cantor
Acting Chief Privacy Officer
Department of Homeland Security