Privacy Impact Assessment

Privacy Impact Assessment
for the

Citizenship and Integration Grant Program
DHS/USCIS/PIA-066
May 19, 2017
Contact Point
Donald K. Hawkins
Privacy Officer
U.S. Citizenship and Immigration Services
(202) 272-8030
Reviewing Official
Jonathan R. Cantor
Acting Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

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Abstract
The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services
(USCIS), Office of Citizenship (OoC), is charged with promoting instruction and training on the
rights and responsibilities of citizenship. Through the Citizenship and Integration Grant Program,
USCIS funds community-based organizations striving to professionalize and increase services to
individuals in the area of citizenship instruction or naturalization application services. USCIS is
conducting this Privacy Impact Assessment (PIA) because the Citizenship and Integration Grant
Program collects, uses, and maintains personally identifiable information (PII).

Overview
The Citizenship and Integration Grant Program is a major part of U.S. Citizenship and
Immigration Services (USCIS) efforts to support effective citizenship preparation services and
provide information to immigrants and public or private nonprofit organizations. Every year,
USCIS accepts applications for the Citizenship and Integration Grant Program, a competitive grant
funding opportunity for organizations that prepare permanent residents for naturalization and
promote civic integration through increased knowledge of civics (United States history and
government) and English (reading, writing, and speaking). USCIS recognizes that naturalization
is an important milestone in the civic integration of immigrants.
The Citizenship and Integration Grant Program is part of a multifaceted effort to provide
citizenship preparation resources, support, and information to immigrants and immigrant-serving
organizations. Recipients are public or private nonprofit organizations with recent experience
providing citizenship instruction and naturalization application services to eligible lawful
permanent residents. They include public school systems, public libraries, community and faithbased groups, adult education organizations, and literacy organizations.
The goal of the Citizenship and Integration Grant Program is to provide support to
community-based organizations in their efforts to establish new citizenship instruction programs
or expand the quality and reach of existing citizenship instruction programs. Through this funding,
USCIS funds community-based organizations striving to professionalize and increase services to
immigrants in the area of citizenship instruction or naturalization application services.
OoC posts Form G-1482, Citizenship and Integration Grant Program, Notice of Funding
Opportunity, to grants.gov. 1 To apply, applicants are required to complete Form Standard Form
(SF)-424, Application for Federal Assistance and Form SF-424A, Budget in accordance with the
application instructions on grants.gov. Information collected about the organization includes the
1

https://www.grants.gov.

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organizational name, address, and type of organization (e.g., community/faith based organization
public school, public library, adult education program). Information collected about the Head of
the Organization Authorized Official or Grant Project Manager includes name, title, address,
phone number, and email address. Applicants are also required to provide the names and resumes
of key personnel in their application package. The notice of funding opportunity instructs
applicants to provide a number of documents (including, project narrative, budget table and
narrative, resumes of key personnel) to be reviewed and scored according to the published
evaluation criteria during the USCIS technical Review process. USCIS requests resumes to assess
an organization’s capacity to provide citizenship instruction and naturalization application
services. Grant applicants upload their complete application packages through grants.gov.
OoC downloads the application packages from grants.gov and stores the packages on a
secured shared drive. After the initial eligibility review is completed, eligible applications are
assigned to independent technical review panels comprised of USCIS personnel. These technical
reviewers use the published selection criteria (originally published on grants.gov) to score their
assigned applications. Technical reviewers score each application package. USCIS ranks the order
of the applications under each funding opportunity based on their average scores. The USCIS
internal review panel then determines the final list of recipients based on the rank order as well as
the published strategic program priorities found in the notice of funding opportunity. Before
making final funding decisions, OoC conducts negotiations with the highest ranking applicants.
OoC then compiles a final list of grant recipients.
Grant Recipient Collaboration Tool
OoC built the Grant Collaboration Tool, a customer relationship management system, to
securely communicate and interact with grant recipients. Grant recipients use the collaboration
tool to send and receive secure communications to OoC staff about their grant, including quarterly
reports. Grant recipients submit their quarterly reports to OoC with a password-protected
Microsoft Excel document. Grant recipient data is only accessible by OoC. Grant recipients are
not able to view or access other grantee data.
Grant recipients may also use the community feature to pose questions to the group. For
example, a grant recipient may ask for recommendations from the group on teaching techniques
that work well with elderly English language learners. Another grant recipient with a large number
of elderly clients may reply with information on their preferred approach. Subject Matter Experts
from OoC may also weigh in on the question. OoC staff may also post questions for group
discussion on the website. For instance, in lieu of a webinar, they may host monthly themes for
discussion on the collaboration tool.

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Accessing the Collaboration Tool
Grant recipients are emailed a link to the system after OoC staff set up a profile for each
recipient. To create a recipient profile in the collaboration tool, OoC creates an account for each
grant point of contact. The account contains the following information: organization name,
description of organization, main phone number, and address (optional entry); the contact contains
the following information: employee title, name, organization name, work phone number, work
email, and work address (optional entry). The account also maintains the following grant
information: grant name, grant number, grant award year, and account name.
After OoC creates a profile for each recipient, the associated contact(s) receive a
“Welcome” email from the collaboration tool with a username and hyperlink to the login page.
Grant Recipients are required to use two factor authentication to gain access to the system. The
associated contact(s) is prompted to enter his or her mobile (work or personal) phone number or
email address on the login page; the system then sends a verification code to the contact(s) via text
message or email. Upon receipt, the contact enters the verification code into the login page. The
system then prompts the contact to create a password with at least eight characters, one letter, and
one number. Contacts do not have to perform two factor authentications for future log-ins after
they have created a password for the system.

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?

Section 538 of the Department of Homeland Security Appropriations Act, 2016 (Pub. L.
No. 114-113), Division F, Title V authorizes USCIS to collect information.

1.2

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

The following Privacy Act System of Records Notices apply to the collection, use,
maintenance, and dissemination of information:
•

2

DHS/USCIS-007 Benefits Information System, 2 covers the collection and use of class
participant information to assess the effectiveness of the grant program.

DHS/USCIS-007 Benefits Information System, 81 FR 72069 (October 19, 2016).

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•

DHS/ALL-004 General Information Technology Access Account Records System, 3 covers
the collection and use of information to provide USCIS employee’s access to the OoC
Grant Collaboration Tool.

•

DHS/ALL-037 E-Authentication Records System of Records, 4 covers the collection and
use of information to authenticate an individual’s identity for the purpose of obtaining a
credential to electronically access the OoC Grant Collaboration Tool.

1.3

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

Yes. The OoC Grant Collaboration tool is covered as a minor application under the
Salesforce Tracking Activities and Relationships System (STARS). USCIS completed the
Salesforce Hosting Environment security assessment and authorization documentation on
December 23, 2016, and was issued a three year Authority to Operate on June 30, 2016.

1.4

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

Yes. GRS 1.2, Items 010, 020, 021. Unaccepted applications (rejected or withdrawn) are
saved on the OoC’s internal shared drive and destroyed when three years old. Accepted
applications are also saved to the shared drive and destroyed 10 years after the last action is taken
on the file. The grant program launched in 2009, and the 15 year requirement to destroy is not
applicable at this time.
Correspondence between individuals or a limited number of participants and quarterly
reporting data will be deleted from the collaboration tool within six months of the end of the
performance period for the grant. Group discussions of grant-related work and promising practices
will be housed indefinitely in the system, provided that the discussion remains relevant, but not
longer than 15 years.

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.

Form G-1482, Citizenship and Integration Grant Program, Notice of Funding Opportunity
is subject to the PRA and is undergoing the OMB approval process. The following forms are
subject to the PRA and obtained OMB approval: Form SF-424, Application for Federal Assistance
3

DHS/ALL-004 General Information Technology Access Account Records System, 77 FR 70792 (November 27,
2012).
4
DHS/ALL-037 E-Authentication Records System of Records, 79 FR 46857(August 11, 2014).

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(OMB No.4040-0004) and Form SF-424A, Budget Information for Non-Construction Programs
(OMB 4040-0006).

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.

As part of the USCIS Citizenship and Grant Integration Program, USCIS OoC collects the
following information:
Application Package
OoC posts the Form G-1482, Citizenship and Integration Grant Program, Notice of
Funding Opportunity, to grants.gov. Applicants are required to provide the names and resumes of
key personnel in their application package. The notice of funding opportunity instructs applicants
to provide a number of documents (i.e., project narrative, budget table and narrative, resumes of
key personnel) to be reviewed and scored according to the published evaluation criteria. Resumes
are required in order to assess organization capacity to provide citizenship instruction and
naturalization application services.
Grant Collaboration Tool
Profiles contain the following information about each user: organization name, description
of organization, organization’s main phone number, and organization’s address (optional entry),
employee names, employee work phone number, employee work email, grant name, grant number,
and grant award year.
Quarterly Report
Grant recipients will report A-Numbers and countries of birth for each individual who
receives citizenship instruction and/or naturalization application services under the grant program.
Additional data elements include: organization name, date enrolled, class number, class level,
pre/post-test used, test scores, date screened, whether the individual self-filed the naturalization
application, date the naturalization application was filed by grantee, date G-28 Notice of Entry of
Appearance as Attorney or Accredited Representative was filed, fee waiver filed by, date Request
for Evidence (RFE) responded by, date passed/failed test, and date oath taken.

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2.2

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

USCIS collects information directly from the grant applicant and recipient. The grant
recipient is responsible for enrolling and collecting information from individuals who receive
instruction from its program. The grant recipient shares limited sensitive biographic information
about its students with USCIS to be used for the internal evaluation of the grant program.

2.3

Does the project use information from commercial sources or
publicly available data? If so, explain why and how this
information is used.

No.

2.4

Discuss how accuracy of the data is ensured.

USCIS OoC collects application and supplemental evidence directly from the public or
private nonprofit organizations seeking a grant under the Citizenship and Integration Grant
Program. Grant recipients are provided access to the collaboration tool for collaboration purposes.
USCIS depends upon the accuracy of the information provided by the grant applicant and recipient.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk of over collection of information for making a grant
determination.
Mitigation: During the information collection review process, the USCIS Privacy Office
reviews forms during the development and revision process to ensure that only the minimum
amount of information is collected to determine grant eligibility. USCIS requires the information
collected to establish and determine grant eligibility of the applicant. All data elements collected
are negotiated with and approved by the Office of Management and Budget (OMB) during PRA
collection review. Furthermore, if grant applicants report more information than necessary, OoC
will destroy sensitive material before saving the applications on the OoC’s internal shared drive.
Unaccepted applications (rejected or withdrawn) are saved on the OoC’s internal shared drive and
destroyed when three years old. Accepted applications are also saved to the shared drive and
destroyed ten years after the last action is taken on the file.

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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.

Application Package
Organizations seeking grant funds for citizenship and naturalization application services
submit an application to USCIS for consideration. The application and supplemental evidence is
required in order for OoC to effectively assess an organization’s capacity to provide citizenship
instruction and naturalization application services. USCIS uses the provided information to
determine which organizations are to be awarded the USCIS Citizenship and Integration Grant
Program.
Grant Collaboration Tool
USCIS uses the OoC Grant Collaboration Tool to communicate with grant recipients. This
system is used in lieu of email to communicate with grant recipients and allows for the secure
exchange of messages and attachments (e.g., instructions, quarterly reports, presentation slides).
This tool expands opportunities for collaboration and sharing of promising practices among grant
recipients.
Quarterly Report
Using Computer Linked Application Information Management System (CLAIMS) 3, 5
CLAIMS 4, 6 and USCIS Electronic Immigration System (USCIS ELIS) 7 databases, the Anumbers collected are used to ascertain general statistics about the individuals who are served by
the grant program, including date of birth, date lawfully admitted for permanent residence, locality,
age, and other factors to be used for the internal evaluation of the grant program. The country of
birth of each individual is used as an easy variable to check the integrity of the data provided by
the grantee against USCIS’ data systems.

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.

No.
5

See DHS/USCIS/PIA-016(a) Computer Linked Application Information Management System (CLAIMS 3) and
Associated Systems, available at www.dhs.gov/privacy.
6
See DHS/USCIS/PIA-015 Computer Linked Application Information Management System (CLAIMS 4), available
at www.dhs.gov/privacy.
7
See DHS-USCIS/PIA-056 USCIS ELIS, available at www.dhs.gov/privacy.

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3.3

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

Yes. DHS Office of Procurement Operations (OPO), Grants and Financial Assistance
Division conducts an initial review of the applications received in response to the Notice of
Funding Opportunity. This review is conducted in accordance with a Memorandum of Agreement
(MOA) between the DHS OPO and USCIS. The MOA, which requires OPO to perform initial
reviews of applications for completeness, responsiveness, and eligibility (among other tasks), is
authorized pursuant to the Economy Act, 31 U.S.C. § 1535 as implemented by the Federal
Acquisition Regulation (FAR) Subpart 17.5. DHS OPO does not have access to the Grant
Collaboration Tool, including the monthly reports.
Additionally, USCIS may also share grant information when there are allegations about
improper use of grant funds with the Inspector General. USCIS will not provide the Inspector
general with direct access to the Grant Collaboration Tool, including the monthly reports.

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that that information may be used outside of the original
purpose for collection, which is to determine grant eligibility, review grant effectiveness, and
provide a space for grant recipients to collaborate.
Mitigation: All records are protected from unauthorized access and use through
appropriate administrative, physical, and technical safeguards that include restricting access to
authorized personnel who have a need-to-know. All grant applications undergo a technical review
process by USCIS personnel. During this process, USCIS personnel review the application
package against published evaluation criteria to score the grant proposal. USCIS limits access to
PII by employing role-based access. All USCIS employees are thoroughly trained regarding the
use and sensitivity of the information. The technical review process requires confidentiality
throughout all proceedings, including the evaluation of proposals. Disclosure of sensitive proposal
selection information or reviewer names and affirmations can be damaging both to DHS and to
the applicants who have entrusted DHS with their proprietary information or intellectual property.
Additionally, all grant reviewers who are USCIS employees must sign a USCIS Conflict
of Interest, Confidentiality and Non-Disclosure Form before the start of the grant review. If at any
time during the evaluation process an unauthorized disclosure or release of privileged information
occurs, a full investigation will be conducted by the appropriate security authorities for appropriate
corrective measures, including but not limited to disciplinary action. USCIS technical reviewers
must destroy all working papers, rough drafts, computation sheets, computer disks, copies or notes
relating to the evaluation process not required for retention in the official proposal selection.

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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.

USCIS provides general notice to individuals through the publication of this PIA and
associated system of record notice (SORN). Additionally, USCIS provides a Privacy Act
Statement prior to the submission of any information, as required by Section (e)(3) of the Privacy
Act. The Privacy Act Statement notifies the individual about the authority to collect the
information requested, purposes, routine uses, and consequences of providing or declining to
provide the information to USCIS. The Privacy Act Statement is included on the collaboration tool
login page and grants.gov, the channel for grant applications.

4.2

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

The Privacy Act Statement informs individuals that providing information is voluntary. A
customer can choose to decline to provide information; however, that may prevent the customer
from participating in the USCIS Office of Citizenship Grant Program.

4.3

Privacy Impact Analysis: Related to Notice

There is no privacy risk related to notice. All information collected by USCIS Office of
Citizenship Grant Program is provided directly from the customer or representative filing for a
benefit request.

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.

Through General Record Schedule (GRS) 1.2, Items 010, 020, 021, unaccepted
applications (rejected or withdrawn) are saved on the Division’s internal shared drive and
destroyed when three years old. Accepted applications are also saved to the shared drive and
destroyed 10 years after the last action is taken on the file. The grant program launched in 2009,
and the 15 year requirement to destroy is not applicable at this time.

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Correspondence between individuals or a limited number of participants and quarterly
reporting data will be deleted from the system within six months of the end of the performance
period for the grant. Group discussions of grant-related work and promising practices will be
housed indefinitely in the system, provided that the discussion remains relevant, but not longer
than 15 years.

5.2

Privacy Impact Analysis: Related to Retention

There is no risk related to retention. Records associated with the USCIS Citizenship and
Integration Grant Program are covered under the General Records Schedule.

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.

Yes. USCIS notifies relevant members of Congress when organizations within their
jurisdiction has been awarded grant funding. 8 After Congress has been notified, DHS emails the
grant award document to grant recipients and notifies the public through a news release. USCIS
publicly releases limited information about organizations that are awarded a grant under the USCIS
Citizenship and Integration Grant Program and the amount of the award. The list of grant recipients
is available on the USCIS website 9 as well as through “Find a Class” on www.myuscis.gov.
USCIS may also share grant information outside of DHS when there are allegations about
improper use of grant funds. Examples include: suspected embezzlement, unauthorized practice
of immigration law, and theft of grant funds. When appropriate, USCIS OoC may share grant
recipient information listed in Section 2.1 of this PIA with and federal, state, and local law
enforcement agencies.

6.2

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

The Privacy Act of 1974 requires executive agencies to publish a SORN whenever a group
of any records under the control of an agency from which information is retrieved by the name of
8
9

See Sec. 507 of Div. F of Pub. L. 114-113
https://www.uscis.gov/citizenship/learners/find-help-your-community.

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the individual or by some identifying number, symbol or other identifying particular assigned to
the individual. One aspect of the SORN is to identify how the information is shared by the agency
(via routine uses section) to external agencies. The SORNs identified in Section 1.2 cover USCIS’
collection, use, maintenance, and sharing of individual information for authentication purposes
while creating system accounts and evaluating the program effectiveness. USCIS does not share
information about individuals with external agencies.
USCIS is sharing information about the grant recipients (i.e., community based
organizations and educational institutions) awarded funding under the USCIS OoC Citizenship
and Integration Grant Program. Grant recipients are organizations, not individuals. Therefore, the
SORN requirement, including routine uses, are not applicable since USCIS is not sharing
information about individuals who received civic instruction or naturalization services from grant
recipients with external agencies.

6.3

Does the project place limitations on re-dissemination?

OoC does not routinely share information about the grant application and collaboration
tool with any agency outside of DHS. USCIS only shares information with authorized entities
when there are allegations of improper use of grant funds.

6.4

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

USCIS maintains records of disclosure of information in accordance with the routine use
set forth in the applicable SORN.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk of unauthorized disclosure of grant recipient information.
Mitigation: USCIS receives the information through the grant application process and
stores it in a secure facility. As part of the USCIS Citizenship and Integration Grant Program,
USCIS publicly releases the organizational name of grant recipients through its website and
through a searchable tool called ‘Find a Class.’ OoC does not routinely share information about
the grant application and collaboration tool with any agency outside of DHS. USCIS will only
share information with authorized entities for an authorized need.

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.

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7.1

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

USCIS creates grant recipients online accounts and are required to authenticate their
identity via a secure login using the username, password, and authentication code. Once
authenticated, individuals may access the information they used to create their profiles, such as
name and address information, as well as their password reset and security questions and answers
on file.
Additionally, an individual seeking access to his or her information may gain access to his
or her USCIS records by filing a Freedom of Information Act (FOIA) or Privacy Act (PA) request
and submitting the requests to following address: USCIS National Records Center. Freedom of
Information Act/Privacy Act Program, P. O. Box 648010, Lee’s Summit, MO 64064-8010. 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?

The collaboration tool allows the grant recipients to directly engage with USCIS and have
access to correct information posted in the tool. Additionally, individuals may direct all requests
to contest or amend information to the FOIA/Privacy Act Office at the USCIS address above.
Individuals must state clearly and concisely in the redress request the information being contested,
the reason for contesting it, the proposed amendment, and clearly mark the envelope “Privacy Act
Amendment.”

7.3

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

USCIS grant application instructions, the USCIS website, this PIA, and the associated
SORNs notify individuals of the procedures for correcting information.

7.4

Privacy Impact Analysis: Related to Redress

There is no privacy risk related to redress with respect to Citizenship and Integration Grant
Program and tool. Individuals may access the information they submit to the collaboration tool at
any time. Additionally, individuals may request access to information about themselves under the
FOIA and Privacy Act.

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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?

USCIS ensures that the practices stated in this PIA are followed by leveraging training,
policies, rules of behavior, and auditing and accountability.

8.2

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

All USCIS federal employees and contractors are required to complete annual privacy and
security awareness training. The Culture of Privacy Awareness training addresses appropriate
privacy concerns, including Privacy Act obligations (e.g., SORN, Privacy Act Statements). The
Computer Security Awareness training examines appropriate technical, physical, personnel, and
administrative controls to safeguard information.

8.3

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

External Users
Employees of grant recipient and employees of sub-awardees of grant recipients that
conduct grant-related work are granted access to the Grant Collaboration Tool. Grant recipients
are separately emailed a link to the system after OoC staff set up a profile for each recipient. To
create a recipient profile in the collaboration tool, OoC creates an account, contact and grant; the
account contains the following information: organization name, description of organization, main
phone number, and address (optional entry); the contact contains the following information:
employee title, name, organization name, work phone number, work email, and work address
(optional entry); the grant contains the following information: grant name, grant number, grant
award year, and account name.
DHS Users
OoC employees who administer the grant and OoC subject matter experts from the
Division of Citizenship Education and Training have access to the Grant Collaboration Tool. To
gain access to the system for new OoC staff, existing OoC send a service item (request) via the
collaboration tool to the OIT Salesforce Support Team (STARS). Once access is granted,
employees are emailed a username and link to the collaboration tool single-sign on login page.

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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 a formal review and approval process in place for new sharing agreements. Any
new sharing agreements, 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
Department of Homeland Security

Approval Signature

Original, signed copy on file with the DHS Privacy Office.

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