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:

G-325A

Form Title:

Biographic Information

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Office of Policy &
Strategy

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
G-325A, Biographic Information
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

1615-0008
Revision

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

June 30, 2017
April 6, 2011

PROJECT OR PROGRAM MANAGER
Frederick Dimichele
Field Operations
Title:
Adjudications Officer
Directorate
202-766-0744
Email:
Frederick.Dimichele@uscis.
dhs.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT

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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:

Frederick Dimichele
Field Operations
Directorate
202-766-0744

Title:

Adjudications Officer

Email:

Frederick.Dimichele@uscis.
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.
Form G-325A is used to collect biographical information in conjunction with certain
USCIS applications or requests. This updated PTA adds the G-325A’s collection in
conjunction with requests for deferred action submitted by certain family members of
active-duty or Selected Reserve of the Ready Reserve military members, veterans, and
enlistees as well as certain enlistees themselves. A separate PTA is being completed for
this information.
USCIS provides deferred action as an exercise of agency discretion to defer the removal
action against certain individuals who are unlawfully present in the United States.
Foreign nationals in the United States may request deferred action by submitting a letter
to USCIS with evidence relevant to their situations. When determining whether to grant
deferred action, USCIS makes a case-by-case discretionary judgment based on the
totality of the evidence. USCIS considers certain factors particularly relevant to the
exercise of discretion, including but not limited to: The fact that the individual
requesting deferred action is a U.S. Department of Defense (DoD) Delayed Entry
Program (DEP) enlistee or the spouse, parent, son, or daughter of a DEP enlistee; or the
fact that the individual would be eligible for parole in placed under separate guidelines
but for the fact that such individual has already been admitted. The existence of one or
more of the above factors does not guarantee a grant of deferred action but may be
considered a strong positive factor when assessing the totality of the facts of the
individual request.
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.
Section 103 of the Immigration and Nationality Act (INA), 8 U.S.C 1103 (a) (1), gives the
Secretary of Homeland Security (the Secretary) general authority to enforce and
administer the immigration laws. On November 15, 2013, pursuant to the authority
conferred upon the Secretary of Homeland Security by INA § 212(d)(5)(A), 8 U.S.C. §
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

1182(d)(5)(A), U.S. Citizenship and Immigration Services (USCIS) issued a Policy
Memorandum (PM) guiding the exercise of discretion with respect to applications for
parole by designated family members of certain U.S. military personnel and veterans.
On November 20, 2014, the Secretary directed USCIS to expand on these policies,
including by issuing new policies on the use of both parole and deferred action for
certain family members of military personnel, veterans, and Department of Defense
(DOD) Delayed Entry Program (DEP) enlistees. In accordance with the Secretary’s
direction, USCIS issued a subsequent PM on November 23, 2016, under the authority
provided by INA § 103(a)(3), 8 U.S.C. 1103(a)(3), to provide the guidance necessary to
carry out the authority provided in 8 U.S.C. 1103(a)(1). PM:
https://www.uscis.gov/sites/default/files/USCIS/Laws/Memoranda/2016/PIPDA_Military_Final_112316.pdf

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?

☒ Yes
☐ No

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

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

c. Who will complete and
submit this 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

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

☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.
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.












Full name
Aliases
Sex
Date of birth
Citizenship/nationality
City and country of birth
Social Security Number, if applicable
Parents’ names, dates of birth, city/country of birth, and city and country of residence
Current and former spouses’ names, dates of birth, dates and places of
marriage/termination
Last 5 years of residence including last address outside the U.S. of more than 1 year
Last 5 years of employment including last occupation abroad

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
☒ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
Privacy Threshold Analysis – IC/Form

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler 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

☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ 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.
INA 264(f). USCIS collects SSNs to verify the identity of the applicant or requestor and
determine eligibility for certain benefits.
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.
USCIS needs the foreign national’s biographic information to verify the identity of the
requestor. USCIS uses the A-number, name, alias, and birth date to determine if the
individual is already in DHS systems and whether he or she has any relevant
immigration history, or if the requestor is in removal proceedings. The address is used to
determine the proper jurisdiction of the application or request and to mail notices, if
applicable. The SSN may be used to verify the identity of the applicant or requestor.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
The records subject, or his or her representative, is
time of collection by
the one filling out the form. There is a Privacy Act
DHS (Does the records
Statement on the form.
subject have notice of
☐ No.
the collection or is
form filled out by
third party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
The form will be maintained in the requestor’s Acompleted IC/forms?
file.
☐ Electronic. Please describe the IT system that will
store the data from the form.
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

☐ 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?

☐ Manually (data elements manually entered). Please
describe.
Click here to enter text.
☐ Automatically. Please describe.
Click here to enter text.

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

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
The A-number is used to query a requestor’s
record in Central Index System.

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
in accordance with
the retention
schedule?

N1- 563-04-03 and N1-566-08-12
Follows same schedule as the A-file retention schedule.
Because a request for deferred action is not a final action,
the A-file will remain active and be stored at the National
Records Center when not in use.

☐ By a non-personal identifier. Please describe.

Records located at individual offices are deleted or
transferred for permanent retention in accordance with
records retention schedules. USCIS mandates that all
employees, civilian or contractor, take annual standard
and electronic records training. This training states that
records management is everyone's responsibility and
provides training on the proper retention of records.
Retired records—those at Federal Records Centers—are
tracked electronically and deleted or transferred for
permanent retention according to the retention schedules.

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

System records will typically have their retentions built
into the system and are deleted or transferred for
permanent retention according to the retention schedules.
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.
Click here to enter text.
☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
☒ 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:

KIM E. MOTT

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

January 4, 2017

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.)

January 6, 2017
☐ 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 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.
Form G-325A is used to collect biographical information in conjunction with certain USCIS
applications or requests. This updated PTA adds the G-325A’s collection in conjunction with
requests for deferred action submitted by certain family members of active-duty or Selected
Reserve of the Ready Reserve military members, veterans, and enlistees as well as certain
enlistees themselves. A separate PTA is being completed for this information.
USCIS provides deferred action as an exercise of agency discretion to defer the removal action
against certain individuals who are unlawfully present in the United States. Foreign nationals in
the United States may request deferred action by submitting a letter to USCIS with evidence
relevant to their situations. When determining whether to grant deferred action, USCIS makes a
case-by-case discretionary judgment based on the totality of the evidence. USCIS considers
certain factors particularly relevant to the exercise of discretion, including but not limited to: The
fact that the individual requesting deferred action is a U.S. Department of Defense (DoD)
Delayed Entry Program (DEP) enlistee or the spouse, parent, son, or daughter of a DEP enlistee;
or the fact that the individual would be eligible for parole in placed under separate guidelines but
for the fact that such individual has already been admitted. The existence of one or more of the

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

above factors does not guarantee a grant of deferred action but may be considered a strong
positive factor when assessing the totality of the facts of the individual request.
The Office of Privacy’s recommendation is to designate this form as privacy sensitive with
coverage under existing PIAs and SORNs.
PIA


DHS/USCIS/PIA-061 Benefit Request Intake Process because this covers the process for
initial intake and receipt of benefit requests submitted by individuals seeking
immigration-related benefits provided in the Immigration and Nationality Act.

SORN
 DHS/USCIS/ICE/CBP-001 Alien File, Index and National File Tracking System of
Records, November 21, 2013, 78 FR 69864 since this is stored with the A file.


DHS/USCIS-007 Benefits Information System, October 19, 2016, 81 FR 72069, since the
purpose of this system is to permit USCIS' collection, use, maintenance, dissemination,
and storage of paper and electronic benefit request 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

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

1137133
January 10, 2017
January 10, 2018

DESIGNATION
Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

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.

DHS IC/Forms Review:

DHS PRIV has approved 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:
Updated system PTA required.
Click here to enter text.
PIA:
PIA Appendix update required
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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-061 Benefit
Request Intake Process
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 Form G-325A, Biographic Information is used
to collect biographical information in conjunction with requests for deferred action
submitted by certain family members of active-duty or Selected Reserve of the Ready
Reserve military members, veterans, and enlistees as well as certain enlistees
themselves.
PRIV finds that is a privacy sensitive system and a PIA is required because PII is
collected from members of the public, specifically applicants, spouse, and potentially
legal representative. PRIV finds that PIA coverage is provided by DHS/USCIS/PIA061 pending a PIA Appendix Update to include Form G-325A, Biographic
Information, the OMB Control Number, and the Case Management System associated
with the form.
PRIV finds that a PAS is required for Form G-325A, Biographic Information because
the form asks members of the public to provide personal information about
themselves which will be stored in a system of record.
PRIV finds that a SORN is required because Form G-325A, Biographic Information
retrieves information by a unique identifier.
PRIV agrees with USCIS Privacy that the A-File SORN and BIS 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,

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

maintenance, dissemination, and storage of benefit request information, including
case processing and decisional data not included in the A-file.
This PTA will expire in one year.

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