Privacy Threshold Analysis

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-1450

Form Title:

Authorization for Credit Card Transactions

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Office of Intake and
Document Production

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Authorization for Credit Card Transactions
OMB Control
Number:
Collection status:
Name:
Office:

Phone:

1615-0131
Revision

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

August 31, 2018
April 24, 2015

PROJECT OR PROGRAM MANAGER
Elizabeth Post
Office of Intake and
Title:
Management and Program
Document Production
Analyst
9132145867/2027404978 Email:
[email protected]
ov

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:

Evadne J. Hagigal
Regulatory Coordination
Division
202-272-0993

Title:

Management and Program
Analyst
Email:
[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. 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.
To provide additional payment options, the USCIS Office of Intake and Document Production (OIDP)
is revising Form G-1450, Authorization for Credit Card Transactions, to collect fees directly
associated with USCIS forms to be processed as payment at the USCIS Lockbox. Initially the G-1450
was only used with the Form N-400, Application for Naturalization. During the expansion phase of
this project the agency is revising Form G-1450 to reflect credit card payment instructions and an
updated Privacy Statement. In addition, the expanded phase will provide USCIS customers the option
to pay approximately 40 benefit request filing fees that are processed through the USCIS Lockbox
with a credit card.
Form G-1450, Authorization for Credit Card Transactions
Form G-1450 is submitted to a Lockbox location together with a benefit request form. Once
received at the Lockbox, information on the G-1450 will be entered into Pay.gov – Trusted
Collection Services (TCS) Interface through an encrypted methodology. Information from the G1450 will not be entered into Lockbox or USCIS IT systems. Once the information has been entered
into Pay.gov, the Form G-1450 will be destroyed.
Form G-1450 collects information about the credit card billing information, as well as the
applicant’s first and last name. This information includes the authorized payment amount and the
payer’s credit card information, including their name, address, signature, telephone number, and
email address. This information is necessary for USCIS to correctly charge the appropriate fee for
the form for which the applicant is applying. The payment information will be solely stored in
Pay.gov.
For successful payments, the Lockbox will generate a bank transaction number, which will be added
to Pay.gov and CLAIMS 3, CLAIMS 4, and ELIS, to link the payment information to the
application. The bank transaction number is generated by the Lockbox and is passed into CLAIMS
3, CLAIMS 4, and ELIS through an existing system interconnection. The bank transaction number
will be added to Pay.gov.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

The G-1450 will be destroyed after the information is entered into Pay.gov whether the payment was
successful or not. If the payment is unsuccessful, the benefit request will be rejected for invalid
payment and the reason is included on the I-797, Notice of Action, which is an existing Lockbox
function.
Relevant Information Technology
All G-1450 information will be processed through The U.S. Department of Treasury’s Pay.gov
system. At no point in time will G-1450 information touch any Lockbox or USCIS IT system.
USCIS CFO and ICE-Burlington Finance Center employees will have access to Pay.gov to perform
payment research.
The applicant’s first and last names are being provided to ensure the correct G-1450 is associated
with the correct benefit request at the Lockbox. This information will not be entered into a USCIS,
U.S. Treasury, or Lockbox information system.

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 information requested on this authorization, and the associated evidence, is
collected under section 286(m) of the Immigration and Nationality Act, 8 U.S.C. 1356(m).
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

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

☒ Yes
☐ No

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

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

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

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

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

☒ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
Individuals who or businesses that make fee
payments on behalf of a beneficiary.

☒ 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.
The purpose of Form G-1450 is to collect credit card and credit billing information to
pay for the fees associated with a benefit request form. There will be no changes to
the data collections. They will remain consistent with the currently approved version
of the form, dated 08/04/17 N. Form G-1450 collects the following information.
Applicant/Petitioner/Requester’s Information:
First Name
Middle Name (if any)
Last Name
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Credit Card Billing Information (Credit Card Holder’s Name as it Appears on the
Card)
First Name
Middle Name (if any)
Last Name
Credit Card Holder’s Billing Address
Street Number and Name
Apt. Ste. Flr. Number
City or Town
State
ZIP Code

Credit Card Holder’s Signature and Contact Information
Credit Card Holder’s Signature
Credit Card Holder’s Daytime Telephone Number
Credit Card Holder’s Email Address

Credit Card Information:
Credit Card Number
Credit Card Expiration Date
Credit Card Type (Visa, Master Card, American Express, Discover)
Authorized Payment Amount

f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☒ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

g. List the specific authority to collect SSN or these other SPII elements.
The information requested on this authorization, and the associated evidence, is
collected under section 286(m) of the Immigration and Nationality Act, 8 U.S.C. 1356(m).

h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
The primary purpose for providing the requested information is to authorize the USCIS
Lockbox to make an electronic credit card payment for the filing fee and biometric
services fee associated with a benefit request form. This is done through the U.S.
Department of Treasury’s Pay.gov Trusted Collection Services (TCS). TCS is a web-based
application that allows Government agencies to process payments by credit or debit
cards. It is owned and operated by the U.S. Department of Treasury,
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at
Form G-1450 includes a USCIS Privacy Notice, and
the time of collection
each Applicant/Petitioner/Requester will receive a
by DHS (Does the
Form I-797 Notice of Action from the Lockbox that
records subject have
their form fee has been paid.
notice of the
☐ No.
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,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.

After USCIS processes the Form G-1450 it will destroy
the authorization, regardless if the agency approves
or denies the accompanying application, petition, or
request. USCIS will not store the credit card
information from the G-1450.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Payment transaction data is maintained in CLAIMS 3,
CLAIMS 4, and ELIS.

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
in accordance with

☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.

☐ Manually (data elements manually entered). Please
describe.
☐ Automatically. Please describe.
Click here to enter text.
N/A. The credit card information is put into U.S.
Department of Treasury’s Pay.gov, not a DHS IT
system.

☐ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
Only the USCIS CFO and ICE Burlington employees
will have access to the U.S. Treasury’s Pay.gov ID
Number.

The G-1450 will be destroyed after the information is
entered into Pay.gov whether the payment was
successful or not.
The Lockbox is ultimately responsible for ensuring
that records are disposed of or deleted in accordance
with the records retention schedule.

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

the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?

☐ Yes, information is shared with other DHS components or offices. Please describe.
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.
The system shares information with the U.S. Department of the Treasury Pay.gov.
There is an MOU between USCIS, U.S. Department of Treasury and the designated
Financial Agent for Lockbox processing of fees and applications.
☐ No. Information on this form is not shared outside of the collecting office.

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

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

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

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

Jenny Hoots
September 1, 2017
September 5, 2017

☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The Office of Privacy recommendation is to designate G-1450 as privacy sensitive
with coverage under the following privacy compliance documentation:
System of Records Notice(SORNs)
•

•

DHS/USCIS/ICE/CBP-001 – Alien File, Index, and National File Tracking System of
Records, which covers the collection of information for applications, petitions, and
benefit requests
DHS/USCIS-007 - Benefits Information System, which covers the collection of
information about the applicant/petitioner/benefit requestor and the
individual/business entity making the fee payment.

Privacy Impact Assessment (PIA)
• DHS/USCIS/PIA-061 Benefit Request Intake Process, which covers the USCIS
Lockbox and fee processing.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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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:

Kameron Cox

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

1149554
September 19, 2017
September 19, 2020

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

DHS PRIV has approved 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 September 18, 2017
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
A privacy notice is required. The privacy notice submitted is
Statement:
adequate.
PTA:
No 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-061 Benefit
Request Intake Process
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/USCIS-007 Benefits
Information System, October 19, 2016, 81 FR 72069
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS is submitting this PTA because it is revising Form G-1450, Authorization for Credit
Card Transactions, to collect fees directly associated with USCIS forms to be processed as
payment at the USCIS Lockbox, reflect credit card payment instructions, update the Privacy
Statement, and expand Form G-1450 to cover 40 benefit request filing fees.
The DHS Privacy Office (PRIV) agrees with USCIS that Form G-1450 is a privacy sensitive
information collection and requires PIA coverage because it collects PII from members of
the public. PRIV concludes that DHS/USCIS/PIA-061, Benefit Request Intake Process,
adequately assesses the privacy risks involved with collecting and manually entering
payment information from paper applications at lockbox facilities.

PRIV finds that a SORN is required because the systems that store the information collected
by Form G-1450 retrieve information by unique identifier. PRIV find that the DHS/USCIS007 BIS SORN covers the collection and dissemination of benefit request information,
including payment information. This program shares PII with the Treasury Department.
This sharing is permitted under Routine Use Z of the BIS SORN and is compatible with the
purpose of the BIS SORN because it allows the Department of Treasury to perform initial
processing of benefit requests and to accept and resolve payment and any related issues.
PRIV finds that a privacy notice is required to provide notice to individuals of the purpose,
authority and disclosures of the information collection of Form G-1450. The privacy notice
USCIS submitted is adequate.

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

APPENDIX A: USCIS/OTHER FORMS
• EOIR-29
• I-102
• I-129F
• I-130
• I-131
• I-140
• I-212
• I-290B
• I-360
• I-485
• I-485A
• I-526
• I-539
• I-600
• I-600A
• I-601
• I-601A
• I-690
• I-694
• I-698
• I-765
• I-800
• I-800A
• I-817
• I-824
• I-821
• I-90
• N-336
• N-400
• N-600
• N-600K
• N-300
• N-470
• G-1041/A
• N-565
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

•

I-910

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