Pta

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

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

I-881

Form Title:

Application for Suspension of Deportation or Special Rule
Cancellation of Removal (Pursuant to Section 203 of Public Law
105-100 (NACARA) here to enter text.

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

RAIO – Asylum
Division

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Click here to enter text.
OMB Control
Number:
Collection status:
Name:
Office:
Phone:

Click here to enter text.
Choose an item.

OMB Expiration
Date:
Date of last PTA (if
applicable):

Click here to enter a
date.
Click here to enter
a date.

PROJECT OR PROGRAM MANAGER
Giacomo A. Picciotto
RAIO-Asylum Division
Title:
Asylum officer
202-272-1620
Email:
[email protected]
hs.gov

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

Name:
Office:

Phone:

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Giacomo A. Picciotto/Cynthia J. Beauchamps
USCIS RAIO-Asylum
Title:
Asylum officer
Division
202-272-1620
Email:
[email protected]
hs.gov
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
Form I-881 Application for Suspension of Deportation or Special Rule Cancellation of
Removal (Pursuant to Section 203 of Public Law 105-100 (NACARA) here to enter text
The PTA expired and requires an update. No changes have been made to Form I-881,
the Form, or the Instructions.
The purpose of this form is to provide a means for eligible aliens to apply for suspension
of deportation of special rule cancellation of removal under section 203 of Public Law
105-100, the Nicaraguan Adjustment and Central American Relief Act (NACARA 203).
The form is intended for:

1. Nationals of El Salvador or Guatemala;
2. Nationals (on December 31, 1991) of Soviet Union, Russia, any Republic of the former
Soviet Union (including Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan,
Moldova, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan), Latvia, Estonia, Lithuania,
Poland, Czechoslovakia, Romania, Hungary, Bulgaria, Albania, East Germany (German
Democratic Republic), Yugoslavia, or any former state of Yugoslavia (including Bosnia
and Herzegovina, Croatia, Kosovo, Macedonia, Montenegro, Slovenia, and Serbia); or
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

3. Spouses, children or unmarried son/daughter of one of the nationals described above
(in addition to other various requirements). Certain individuals who have been battered
or subjected to extreme cruelty, can also use this form if they meet the other various
requirements.

Information from the form is entered in the Refugees, Asylum and Parole System (RAPS).
The form is placed in the Alien File and is forwarded to a USCIS Asylum Office for
interview and adjudication. If the applicant is ineligible, the form is referred to the
Department of Justice, Executive Office for Immigration Review, for further review.
b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
The authority to collect information in this form is set forth in the Immigration and
Nationality Act, 8 U.S.C. §§ 1103, 1158, 1225, 1228, and Title II of Public Law 105-100
and in the implementing regulations found in volume 8 of the Code of Federal
Regulations (CFR).

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

1
Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.

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

c. Who will complete and
submit this form? (Check
all that apply.)

d. How do individuals
complete the form? Check
all that apply.

☒ The record subject of the form (e.g., the
individual applicant).
☒ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.

☒ Paper.
☐ Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
Public

The form collects an individual’s: Alien Number, Complete Name, Aliases,
Complete Address, Date of Birth, Place of Birth, Social Security Number, Gender,
Citizenship, Home Phone Number, Past residences addresses and dates of
residing, U.S. entry date(s), Port(s) of entry, Status upon entry(ies), Name used on
first entry, period(s) admitted, change(s) of status, date(s) of status change,
port(s) of departure, date(s) of departure, reason for traveling pertaining to each
departure, destination, status at entry, inspection results, immigration
deportation/removal information, information about presence in the U.S.,
financial status and employment information, marital status/spouse information,

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

information about child(ren), information about parent(s) and information about
applicant’s habits/lifestyle.
Preparer/Attorney (see comment 2c): Attorney State License Number. Signature,
name, telephone number and complete address of the person who prepared the
application.

f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
☒ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☒ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☒ Visa Number
☐ Trusted Traveler Number (Global
☒ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:

g. List the specific authority to collect SSN or these other SPII elements.
Immigration and Nationality Act, 8 U.S.C. §§ 1103, 1158, 1225, 1228, and Title II of Public
Law 105-100 and in the implementing regulations found in volume 8 of the Code of
Federal Regulations (CFR).
h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
The SSN information and other SPII elements are collected within the form I-881
application is used to assist the DHS in establishing eligibility for the benefit being
sought, as well as enforcing the immigration laws of the United States by providing
timely and accurate information about persons who are subject to those laws. The SSN is
used to verify the identity of the applicant and dependents.

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

i.

Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

☒ Yes. Please describe how notice is provided.
A Privacy Act Statement is provided with the form
instructions.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
The paper application will be housed in the
completed
applicant’s A-File.
IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
Some information is entered in the Refugee, Asylum
and Parole System (RAPS), a System of Records
database
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the electronic
repository.
Click here to enter text.
b. If electronic, how
does DHS input the
responses into the
IT system?

Privacy Threshold Analysis – IC/Form

☒ Manually (data elements manually entered). Please
describe.
Upon receipt of the application, some information is
typed-in and entered in the Refugee, Asylum and
Parole System (RAPS), a system of records database.
☐ Automatically. Please describe.
Click here to enter text.

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

c. How would a user
search the
information
submitted on the
forms, i.e., how is
the information
retrieved?

d. What is the records
retention
schedule(s)?
Include the records
schedule number.

☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
If the applicant doesn’t already have an A-File
Number assigned at time of application, an A-File
number is assigned upon receipt of Form I-881. The
A-File is stored in an electronically trackable
location and retrieved when needed. The
information may be retrieved by A-Number in NFTS,
RAPS, or A-Number, name and date of birth in RAPS.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
As directed by File Plan.
The form is placed into the A-File and becomes a
permanent part of the file. It’s under the RAPS
system schedule under the Inputs section. You can
review the schedule via the link below.

https://www.archives.gov/recordsmgmt/rcs/schedules/departments/departmentof-homeland-security/rg-0563/n1-563-04006_sf115.pdf
DISPOSITION:
a. Electronic records.
TEMPORARY. Destroy/Delete after the data has
been transferred to the master file and verified.
b. Paper records, Form 1-589 "Application for
Asylum and Withholding or Removal," and Form 1881, "Application for Suspension of Deportation or
Special Rule Cancellation."
Place in the applicant's A-File.
DISPOSITION:

2
Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.

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

a. Complete system. Restrictions per 5 U.S.C. 552(b)
(3)
PERMANENT. Copy data offline annually after case
is closed. Transfer to the National Archives after 25
years in accordance with 36 CFR 1228.270. Public
access restricted for 75 years after close of case.

Public use version. Consists of redacted copy of item
2a with personal identifiers removed.
PERMANENT. Copy data offline annually after case
is closed. Transfer to the National Archives after 25
years in accordance with 36 CFR 1228.270.
Note: The redacted version becomes obsolete when
the unredacted version becomes public.
e. How do you ensure The system owner is responsible for ensuring the records
are deleted in accordance with the approved records
that records are
retention schedule.
disposed of or
deleted in
accordance with the
retention schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☒ Yes, information is shared with other DHS components or offices. Please describe.
If the benefit application is not granted, USCIS lacks authority to deny it and
the application is referred to the Executive Office for Immigration Review,
an agency of the Department of Justice, for an immigration judge to
determine if it should be approved or denied. At that time, a copy of the
application is shared with DHS - Immigration and Customs Enforcement, the
agency charged with representing DHS in proceedings before the
immigration judge.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

The information may be shared with law enforcement agencies in the context of a
criminal investigation, or prosecution.
☐ No. Information on this form is not shared outside of the collecting office.

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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

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

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

Kim Mott
December 20, 2016
December 21, 2016
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
PAS is currently in review with OCC.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
Form I-881, Application for Suspension of Deportation or Special Rule Cancellation of
Removal (Pursuant to Section 203 of Public Law 105-100, NACARA)

The form collects an individual’s: Alien Number, Complete Name, Aliases, Complete
Address, Date of Birth, Place of Birth, Social Security Number, Gender, Citizenship, Home
Phone Number, Past residences addresses and dates of residing, U.S. entry date, Port of
entry, Status upon entry, Name when entering on first entry, period admitted, change of
status, date of status change, port of departures, departures date, reason for traveling,
destination, status at entry, inspection results, immigration deportation/removal
information, information about your presence in the U.S., Financial status and employment
information, marital status/spouse information, information about child(ren), information
about parent(s) and information about applicants habits/lifestyle.

USCIS recommend coverage under:
• DHS/USCIS/PIA-027(b) Refugee, Asylum, and Parole System (RAPS) and the Asylum
Pre-Screening System (APSS) Update
• DHS/USCIS-010 Asylum Information and Pre-Screening System of Records

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

•

Form will require a Privacy Act (e)(3) Statement

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

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

Max Binstock

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1136553
December 28, 2016
December 28, 2019

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

DHS PRIV has not received this ICR/Form.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☐ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☒ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
New e(3) statement is required.
Statement:
Click here to enter text.
PTA:
New system PTA required.
Click here to enter text.
PIA:
System covered by existing PIA
If covered by existing PIA, please list:

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

If a PIA update is required, please list: DHS/USCIS/PIA-027 Refugee,
Asylum, and Parole System (RAPS) and the Asylum Pre-Screening
System (APSS) Update
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/USCIS-010 Asylum
Information and Pre-Screening System of Records
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS is submitting this PTA to document Form I-881, which provides a means for
eligible aliens to apply for suspension of deportation of special rule cancellation of
removal under section 203 of Public Law 105-100, the Nicaraguan Adjustment and
Central American Relief Act (NACARA 203).
PRIV finds that is a privacy sensitive system and a PIA is required because Form I881 collects PII from members of the public. PRIV finds that the forthcoming rewrite to the RAPS APSS PIA (the Asylum Program PIA), will provide significant
coverage. DHS/USCIS/PIA-027 and the forthcoming Asylum Program PIA cover this
this form and discusses its relation to the asylum program.
PRIV finds that a SORN is required because Form I-881 retrieves information by a
unique identifier. PRIV agrees with USCIS Privacy that the Asylum Information and
Pre-Screening SORN provides coverage. DHS/USCIS-010 covers information stored in
physical documents and supplemental documentation in the Alien File and
processes asylum, NACARA and follow-to-join applications, and credible fear or
reasonable fear determinations in the respective case management system.
Final SORN coverage will be determined during the Asylum Program PIA re-write.

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