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.
Privacy Threshold Analysis – IC/Form

Page 1 of 13

Version number: 04-2016

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:

Form I-730

Form Title:

Refugee/Asylee Relative Petition

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office: RAIO
and SCOPS

Click here to enter text.

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

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

Choose an item.

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

PROJECT OR PROGRAM MANAGER
William Tomlyanovich and Roman Ginzburg
SCOPS/ANTZ, RAIO/IO
Title:
Adjudications Officer
202-272-1384, 202-272Email:
William.J.Tomlyanovich@us
8605
cis.dhs.gov,
[email protected].
gov

Privacy Threshold Analysis – IC/Form

Page 2 of 13

Version number: 04-2016

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
William Tomlyanovich and Roman Ginzburg
SCOPS/ANTZ, RAIO/IO
Title:
Adjudications Officer
202-272-1384, 202-272Email:
William.J.Tomlyanovich@us
8605
cis.dhs.gov,
[email protected].
gov
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form.

USCIS is extending/renewing Form I-730, Refugee/Asylee Relative petition. The form allows
Principal Refugees and Asylees to petition for their spouse and children. If the petitioner has
been admitted to the United States as a principal refugee or if he/she was granted status in the
United States as a principle asylee within the previous two years, the petitioner may file a
Form I-730 to request follow-to-join benefits for his/her spouse and/or unmarried children
under 21 years of age only. See Form I-730 instructions for further information.
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)?

☒ Yes
☐ No

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.

Privacy Threshold Analysis – IC/Form

Page 3 of 13

Version number: 04-2016

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

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

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

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

Privacy Threshold Analysis – IC/Form

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

Some petitioners are lawful permanent residents
(LPRs) and some are refugees or asylees.
Beneficiaries are non-US persons.
☒ 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.
The petitioner or the petitioner’s legal
representative will fill out the form.

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

Page 4 of 13

Version number: 04-2016

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

This form is not currently in ELIS. The electronic
version can be found here: https://www.uscis.gov/i730
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.
The form is filled out by the petitioner, beneficiary or by the petitioner’s representative.
Petitioner and Beneficiary
Form I-730 will continue to collect the following information from the petitioner and
beneficiary to determine benefit eligibility: full name, alias, mailing address, telephone
number, email, gender, date and country of birth, Alien Number, Social Security Number (if
applicable), status, nationality, citizenship, relationship between the petitioner and beneficiary,
marital status, date of marriage, date of divorce, former spouse name, date of asylum grant or
refugee admission, date of arrival in USA, I-94, Passport Number, Travel Document Number,
Country of Issuance for Passport or Travel Document and Expiration Date for Passport or
Travel Document, and native language.
The form instructions also instruct the petitioner to submit verifying evidence to show that the
petitioner is eligible to file Form I-730, e.g. evidence of status as refugee or asylee, and that a
familial relationship exists between the petitioner and alien relative at the time the petitioner
were admitted as a refugee or granted asylum in the United States, e.g., beneficiary’s birth or
marriage certificate.
USCIS uses this information and collected biometrics (beneficiary’s fingerprints and photo) to
conduct enhanced security checks, interview beneficiaries and verify the authenticity of their
original documents or collect additional documentary evidence to verify identity and
qualifying relationship, as well as probe criminal, terrorist, persecutor and national securityrelated ineligibility grounds.
Petitioner Representative
As part of standard language updates, Form I-730 will now include a signature section for the
interpreter and preparer. These sections collect the interpreter’s and preparer’s contact
information such as daytime telephone number and firm name, address, and email address (if
any), certification, and signature.
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)
Privacy Threshold Analysis – IC/Form

Page 5 of 13

Version number: 04-2016

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

☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☒ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
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).
The SSN information collected within the Form I-730 application is used to assist the DHS in
enforcing the immigration laws of the United States by providing timely and accurate
information about persons who are subject to those laws.
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.
Under the current process, the Nebraska and Texas Service Centers adjudicate the I-730
petition for overseas beneficiaries without the benefit of an interview and beneficiary
biometric and enhanced security checks. Service Centers send approved petitions, via the
National Visa Center (NVC), to a Refugee, Asylum and International Operations (RAIO) field
office or Department of State (DOS) consular post for travel document processing. Prior to
issuing travel documents, RAIO or DOS officers (overseas officers) collect biometrics and
conduct enhanced security checks, interview beneficiaries and verify the authenticity of their
original documents or collect additional documentary evidence to verify identity and
qualifying relationship, as well as probe criminal, terrorist, persecutor and national securityrelated ineligibility grounds.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
There is a Privacy Act Statement on the form.
time of collection by
☐ No.
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

Privacy Threshold Analysis – IC/Form

Page 6 of 13

Version number: 04-2016

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

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
A-files
completed IC/forms?
☐ Electronic. Please describe the IT system that will

b. If electronic, how
does DHS input the
responses into the IT
system?
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.

e. How do you ensure
that records are
disposed of or deleted

store the data from the form.
Click here to enter text.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.

☐ Manually (data elements manually entered). Please
describe.
Click here to enter text.
☐ Automatically. Please describe.
Click here to enter text.
☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
A-number
☐ By a non-personal identifier. Please describe.
Click here to enter text.

SCOPS/RAIO defers to the Records Officer.
The I-730 form is A-File material, meaning it should be
placed into the Alien File and retained in accordance with
the A-File retention schedule.
NC1-85-80-5/1

Program office following the records retention schedule
for filing and destruction of records.

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.

Privacy Threshold Analysis – IC/Form

Page 7 of 13

Version number: 04-2016

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

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?
Service Centers send approved petitions, via the National Visa Center (NVC), to a Refugee,
Asylum and International Operations (RAIO) field office or Department of State (DOS)
consular post for travel document processing. DOS consular officers interview some
beneficiaries to verify eligibility for travel.
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).
☒ Yes, information is shared with other DHS components or offices. Please describe.
Information from Form I-730 is entered into CLAIMS 3 for adjudication and the supplemental
documents are stored in the A-File. International Field Offices will also update CAMINO with
case information and an adjudicative decision for transferred cases. Once a case has been
adjudicated, IO will update data from CAMINO into CLAIMS 3 servers to update the
CLAIMS 3 petition records.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.

Please describe applicable information sharing governance in place:

MOA between DOS and DHS regarding the sharing of VISA and passport records and
immigration and naturalization and citizenship records.
Routine Use of the BIS SORN, which permits the sharing of information with DOS for the
purpose of assisting in the processing of petitions or applications for benefits.
☐ No. Information on this form is not shared outside of the collecting office.

Privacy Threshold Analysis – IC/Form

Page 8 of 13

Version number: 04-2016

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

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

Privacy Threshold Analysis – IC/Form

Page 9 of 13

Version number: 04-2016

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
January 13, 2017
January 24, 2017

☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Click here to enter text.
USCIS Office of Privacy developed a Privacy Act
Statement and is seeking program and OCC
approval.
Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
USCIS is extending/renewing Form I-730, Refugee/Asylee Relative petition. The form allows
Principal Refugees and Asylees to petition for their spouse and children. If the petitioner has
been admitted to the United States as a principal refugee or if he/she was granted status in the
United States as a principle asylee within the previous two years, the petitioner may file a Form
I-730 to request follow-to-join benefits for his/her spouse and/or unmarried children under 21
years of age only.
The Office of Privacy recommends this form is privacy sensitive with coverage under existing
PIAs and SORNs.
PIA
•

•

DHS/USCIS/PIA-16(a) Computer Linked Application Information Management System
(CLAIMS 3) and Associated System since information is entered into CLAIMS 3 and
listed in the PIA.
DHS/USCIS/PIA-051 Case and Activity Management for International Operations
(CAMINO) which is used to support Refugee, Asylum and International Operations
(RAIO) International Operations (IO). It’s a case management system designed to

Privacy Threshold Analysis – IC/Form

Page 10 of 13

Version number: 04-2016

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

facilitate the processing of immigrant applications and petitions received or adjudicated
by RAIO IO.
SORN
• DHS/USCIS/ICE/CBP-001 Alien File, Index and National File Tracking System of
Records, November 22, 2013, 78 FR 69864 since the information is stored in the A file.
• DHS/USCIS-007 Benefits Information System, October 19, 2016, 81 FR 72069 USCIS'
collection, use, maintenance, dissemination, and storage of paper and electronic benefit
request information. These records assist in the processing of immigrant and
nonimmigrant benefit requests from the time when USCIS collects the information from
the benefit requestor until the case reaches a final decision in the relevant case
management system.
• DHS/USCIS-010 Asylum Information and Pre-screening System of Records, November
30, 2015, 80 FR 74781 since the purpose of this SORN is to manage, control, and track
follow-to-join derivative asylum/refugee cases (Form I-730) under 8 CFR 208.21.

Privacy Threshold Analysis – IC/Form

Page 11 of 13

Version number: 04-2016

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:

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date
Privacy Sensitive IC or
Form:
Determination:

DHS IC/Forms Review:

Max Binstock
1137733
January 31, 2017
January 31, 2020

DESIGNATION
Yes If “no” PTA adjudication is complete.
☐ 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.
DHS PRIV has not received this ICR/Form.

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: DHS/USCIS/PIA-051 Case and
Activity Management for International Operations (CAMINO);

Privacy Threshold Analysis – IC/Form

Page 12 of 13

Version number: 04-2016

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

DHS/USCIS/PIA-016(a) Computer Linked Application Information
Management System (CLAIMS 3) and Associated Systems
If a PIA update is required, please list: Click here to enter text.
SORN:
SORN update is required.
If covered by existing SORN, please list: DHS/USCIS/ICE/CBP-001 Alien
File, Index, and National File Tracking System of Records, November 21,
2013, 78 FR 69864; DHS/USCIS-010 Asylum Information and PreScreening System of Records, November 30, 2015, 80 FR 74781
If a SORN update is required, please list:
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS Privacy is submitting this PTA because Form I-730, Refugee/Asylee Relative
petition allows Principal Refugees and Asylees to petition for their spouse and
children. If the petitioner has been admitted to the United States as a principal
refugee or if he/she was granted status in the United States as a principle asylee
within the previous two years, the petitioner may file a Form I-730 to request followto-join benefits for his/her spouse and/or unmarried children under 21 years of age
only.
PRIV finds that is a privacy sensitive system and a PIA is required because From I730 collects PII from members of the public. PRIV agrees with USCIS Privacy that the
CAMINO PIA and CLAIMS 3 PIA provides coverage. DHS/USCIS/PIA-051 discusses the
case management system designed to facilitate the processing of immigrant
applications and petitions received or adjudicated by RAIO IO. DHS/USCIS/PIA016(a) discusses the processing of the form in CLAIMS 3.
PRIV finds that a SORN is required because Form I-730 retrieves information by a
unique identifier. PRIV agrees with USCIS Privacy that the A-File, Index, and National
File Tracking SORN and Asylum Information and Pre-screening SORN provide
coverage. DHS/USCIS/ICE/CBP-001 covers information stored in the A-File.
DHS/USCIS-010 covers records collected in follow-to-join derivative asylum/refugee
cases (Form I-730) under 8 CFR 208.21.
PRIV also finds that a PAS is required because Form I-730 asks persons to provide
personal information about themselves, which will go into a system of records.

Privacy Threshold Analysis – IC/Form

Page 13 of 13

Version number: 04-2016