Privacy Threshold Assessment

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:

N-426

Form Title:

Click here to enter text.
Request for Certification of Military or Naval Service
U.S. Citizenship and
Office:
Service Center
Immigration Services
Operations
(USCIS)

Component:

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form N-426, Request for Certification of Military or Naval Service
OMB Control
Number:
Collection status:
Name:
Office:
Phone:
Name:

1615-0053
Extension

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

March 29, 2016
March 26, 2016

PROJECT OR PROGRAM MANAGER
Natalie O’Connor
Service Center Operations
Title:
Adjudications Officer
202-272-2924
Email:
Natalie.A.O’[email protected]
s.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Cynthia Beauchamps

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

Office:

Phone:

Regulatory Coordination
Division
202-272-2948

Title:

Email:

Project Manager

Cynthia.J.Beauchamps@usci
s.dhs.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.
Click here to enter text.
Persons who are serving or have served under specified conditions in the Armed
Forces of the United States are granted certain exemptions from the general
requirements for naturalization. To establish eligibility, the law requires the
departments with custody of the service records to certify when the service
member served and whether each separation from the service was under
honorable conditions. Applicants obtain the completed Form N-426 from the
certifying official and submit the form with Form N-400, Application for
Naturalization. USCIS uses Form N-426 to establish honorable military service of
an applicant under sections 328 or 329 of the Immigration and Nationality Act
(INA).
Current or former members of the U.S. Armed Forces who are applying for
naturalization under section 328 or 329 of the INA submits the following with
Form N-426:
1. Form N-400, Application for Naturalization, and
2. Copy of Form DD-214 Certificate of Release of Discharge from Active Duty,
or NGB Form 22, National Guard Report of Separation and Records of
Service.
The purpose of Form N-426 is for the Department of Defense to verify an
applicant’s military or naval service. Form N-426 is submitted to the branch of the
U.S. military service that the naturalization applicant is currently serving or had
served for certification of military service. Completion and certification of this
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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 by the applicant and certifying official serve as an authenticated certification
of military service.

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.
Click here to enter text.
Primary authorizing legislations: Sections 328 and 329 of Immigration and
Nationality Act (the INA) and Title 8 of Code of Federal Regulations (8 CFR) Parts
328 and 329.

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.)

c. Who will complete and
submit this form? (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.

☒ 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?

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

☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
Certain Service Members, civilian employees,
or contractors of the Department of Defense
may act as conduits and submit the form in
response to a request for evidence (RFE) by
USCIS on behalf of the Service Member and
with the expressed permission and consent of
the Service Member.
d. How do individuals
complete the form? Check
all that apply.

☒ 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.
Form N-426 collects the individual’s name, address, social security number, alien
number, military service number, date of birth, phone number, e-mail address,
place of birth, military history, and signature of the applicant. The form also
collects the certifying official’s name, title, phone number, email address, 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)

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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.
Click here to enter text.
INA Sec. 290. [8 U.S.C. 1360]: (a) There shall be established in the office of the
Commissioner, for the use of the security and enforcement agencies of the
Government of the United States, a central index, which shall contain the names of
all aliens heretofore admitted or denied admission to the United States, insofar as
such information is available from the existing records of the Service, and the
names of all aliens hereafter admitted or denied admission to the United States,
the names of their sponsors of record, if any, and such other relevant information
as the Attorney General shall require as an aid to the proper enforcement of this
Act.
(b) Any information in any records kept by any department or agency of the
Government as to the identity and location of aliens in the United States shall be
made available to the Service upon request made by the Attorney General to the
head of any such department or agency.
(c) 1/ (1) Not later than 3 months after the end of each fiscal year (beginning with
fiscal year 1996), the Commissioner of Social Security shall report to the
Committees on the Judiciary of the House of Representatives and the Senate on the
aggregate quantity of social security account numbers issued to aliens not
authorized to be employed, with respect to which, in such fiscal year, earnings
were reported to the Social Security Administration.
(2) If earnings are reported on or after January 1, 1997, to the Social Security
Administration on a social security account number issued to an alien not
authorized to work in the United States, the Commissioner of Social Security shall
provide the Attorney General with information regarding the name and address of
the alien, the name and address of the person reporting the earnings, and the
amount of the earnings. The information shall be provided in an electronic form
agreed upon by the Commissioner and the Attorney General.
(d) A written certification signed by the Attorney General or by any officer of the
Service designated by the Attorney General to make such certification, that after
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

diligent search no record or entry of a specified nature is found to exist in the
records of the Service, shall be admissible as evidence in any proceeding as
evidence that the records of the Service contain no such record or entry, and shall
have the same effect as the testimony of a witness given in open court.

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.
Click here to enter text.
Information collected will be used to verify the applicant’s Characterization of
Service as required under Sections 328 and 329 of the INA. The required
information assists Immigration Services Officer in determining the applicant’s
eligibility for the benefit sought.

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.
Click here to enter text.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
Form N-426 will be stored in the individual’s
completed IC/forms?
USCIS administrative file.
☐ Electronic. Please describe the IT system that will
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.

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

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.

☐ 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.
The information can be searched by the alien
registration number or receipt number.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
The National Archives and Record’s
Administration (NARA) approved retention
schedule [N1-563-04-004] has not changed.
Records in CLAIMS 4 will be deleted 15 years after
the application for naturalization is approved,
denied, or withdrawn and any appeals process, if
applicable is completed. Information is destroyed
15 years after the last completed action with
respect to the application, which is stored in the
applicant’s alien file (A-file).
https://www.archives.gov/recordsmgmt/rcs/schedules/departments/department-ofhomeland-security/rg-0563/n1-563-04-004_sf115.pdf

The A-file NARA approved retention schedule [N1566-08-11] has been updated. Previous
encounter information maintained in the A-file
will now be retained in accordance with the A-file
retention schedule, which is 100 years from the
applicant’s DOB; there after the file is retired to
NARA as a permanent record.
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

e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?

CLAIMS 4 will be deleted 15 years after the
application for naturalization is approved, denied,
or withdrawn and any appeals process, if
applicable, is completed. Information is destroyed
fifteen years after the last completed action with
respect to the application, which is stored in the
applicant’s A-file. https://www.archives.gov/recordsmgmt/rcs/schedules/departments/department-of-homelandsecurity/rg-0566/n1-566-08-011_sf115.pdf

Information maintained in the A-File will now be
retained in accordance with the A-File retention
schedule, which is 100 years from the applicant’s
DOB; there after the file is retired to NARA as a
permanent record.
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.
Partner DHS entities may obtain rudimentary information on the applicant
only, along with the form receipt number, via Person Centric Query System
(PCQS)

☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.

☐ No. Information on this form is not shared outside of the collecting office.

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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.

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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.)

Brian E. Anderson
November 22, 2016
November 29, 2016
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
USCIS Office of Privacy developed a Privacy
Act Statement and is seeking 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.
Form N-426, Request for Certification of Military or Naval Service (OMB Control Number 16150053). Persons who are serving or have served under specified conditions in the Armed Forces of
the United States are granted certain exemptions from the general requirements for naturalization.
To establish eligibility, the law requires the departments with custody of the service records to
certify when the service member served and whether each separation from the service was under
honorable conditions. Applicants obtain the completed Form N-426 from the certifying official and
submit the form with Form N-400, Application for Naturalization. USCIS uses Form N-426 to
establish honorable military service of an applicant under sections 328 or 329 of the Immigration
and Nationality Act (INA).

USCIS Privacy recommendation is to designate N-426 as a privacy sensitive form with coverage
under DHS/USCIS/PIA-015(b) - Computer Linked Application Information Management System 4
(CLAIMS 4) Update, DHS/USCIS-007 Benefits Information System SORN, and DHS/USCIS/CBP/ICE001 A-File SORN. Further, a Privacy Act Statement is in progress. Also, PAS is required.
OMB Control Number: 1615-0053

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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

1135615
December 1, 2016
December 1, 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
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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 covered by existing PIA, please list: DHS/USCIS/PIA-015 Computer
Linked Application Information Management System (CLAIMS 4) Update
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/USCIS/ICE/CBP-001 Alien
File, Index, and National File Tracking System of Records, November 21,
2013, 78 FR 69864; DHS/USCIS-007 Benefits Information System
October 19, 2016, 81 FR 72069
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 because USCIS uses Form N-426 to establish honorable
military service of an applicant under sections 328 or 329 of the Immigration and
Nationality Act (INA).
PRIV finds that is a privacy sensitive system and a PIA is required because USCIS
collects PII from members of the public and other federal employees or contractors.
PRIV agrees with USCIS that the CLAIMS 4 PIA provides adequate coverage.
DHS/USCIS/PIA-015 discusses the processing and adjudicating of N-400 Applications
for Naturalization and supplemental documents such as N-426. PRIV recommends
submitting a list of all the supplemental forms to the N-400 to add as an Appendix to
the CLAIMS 4 PIA.
PRIV finds that a SORN is required because Form N-426 retrieves information by a
unique identifier. PRIV agrees with USCIS Privacy recommendation that the BIS
SORN and A-File SORN provide adequate coverage. DHS/USCIS/ICE/CBP-001 covers
the paper and electronic copy A-File and/or Receipt File, supplemental forms,
supplemental evidence, and identity history summaries (formally known as RAP
sheets), but does not include all case processing and decisional data. DHS/USCIS-007
covers USCIS' collection, use, maintenance, dissemination, and storage of benefit
request information, including case processing and decisional data not included in
the A-file.
PRIV finds that a PAS is also required.

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