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:

N-445

Form Title:

Notice of Naturalization Oath Ceremony

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Field Operations
Directorate

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
N-445, Notice of Naturalization Oath Ceremony
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:

1615-0054
Revision

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

June 30, 2019
Click here to enter
a date.

PROJECT OR PROGRAM MANAGER
James Weidemann
Field Operations
Title:
Adjudications Officer
410-740-1426
Email:
[email protected]
hs.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Kerstin Jager

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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
202 213 4211

Title:

Management and Program
Analysis
Email:
[email protected]
v
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.
USCIS is responsible for the adjudication of all applications and petitions for
immigration benefits in accordance with applicable laws, regulations, and
procedures.
The Form N-445, Notice of Naturalization Oath Ceremony, was first used by legacy
Immigration and Naturalization Service, and continues to be used by U.S.
Citizenship and Immigration Services (USCIS) to notify applicants to appear (on a
specific date and time) at a naturalization ceremony for administration of the oath
of allegiance. The use of Form N-445 is mandated by federal regulation.
In addition to notifying applicants of a scheduled naturalization ceremony, Form
N-445 is also used to verify an applicant’s continued eligibility for naturalization.
The form contains a series of questions that must be answered by the applicant.
The questions are designed so that USCIS officials can determine if an applicant
has continued to maintain “good moral character” from the date of the interview
up until the day of the naturalization ceremony. Failure on the part of the
applicant to maintain “good moral character” prior to the naturalization ceremony
may result in the applicant’s removal from the ceremony in order for USCIS to
conduct further review.
Since the 2016 PTA, USCIS has added a QR code to the form. USCIS preprints
applicant data (name, address, alien registration number) on Form N-445 before
mailing it to the applicant through the U.S. Postal Service. In addition to the
preprinted applicant data, USCIS also prints a machine-readable QR code on the NPrivacy Threshold Analysis – IC/Form

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

445 notice associated with an N-400 application that was filed electronically
through the applicant’s USCIS online account. The QR code contains only the IOE
number (i.e. the receipt number for an electronically filed application).
Additionally, since the 2016 PTA, the N-445 is now also processed in CLAIMS 4.
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.
Authority for collection of the information requested on Form N-445 is contained
in Sections 101(f), 313, 316, 332, 334, 335, and 336 of the Immigration and
Nationality Act (8 U.S.C. 1101(F), 1427, 1443, 1445, 1446, and 1447).

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

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

☐ No
☐ 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.
USCIS preprints applicant data (name, address, alien registration number) on
Form N-445 before it is mailed to the applicant through the U.S. Postal Service.
USCIS will also print a machine- readable QR code on N-445 notices associated
with an N-400 application that was filed electronically through the applicant’s
USCIS online account. The QR code contains only the IOE number (i.e. the receipt
number for an electronically filed application).
The applicant is asked to answer questions that are used by USCIS to determine
continued eligibility for naturalization. After an applicant answers the questions,
they must affirm their responses by means of their signature, date, and address.
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.)
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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:

☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
Authority for collection of the information requested on Form N-445 is contained
in Sections 101(f), 313, 316, 332, 334, 335, and 336 of the Immigration and
Nationality Act (8 U.S.C. 1101(F), 1427, 1443, 1445, 1446, and 1447).
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 purpose of collecting the Alien Registration Number is to ensure association of
the Form N-445 with the correct USCIS record.
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.
A Privacy Act Statement is included on the Form,
USCIS Office of Privacy is working to update the
current Statement to a Notice.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
The N-445s will be manually recorded into the
completed IC/forms?
CLAIMS 4 system before they are stored in the
respective physical A-file.
☒ Electronic. Please describe the IT system that will
store the data from the form. CLAIMS 4 and ELIS
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.

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

USCIS will scan and upload the completed form in
USCIS ELIS (USCIS Electronic Immigration System),
after which the paper form will be destroyed (for new
N-400 filings).

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

☒ Manually (data elements manually entered). Please
describe.
USCIS adjudicators manually enter information
from the paper N-445 into CLAIMS 4, or the N-445
is scanned into USCIS ELIS.
☐ 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?
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?

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Alien Registration Number (A-Number)
☐ By a non-personal identifier. Please describe.
Click here to enter text.
The Form N-445 is ultimately stored in the A-file,
which is permanently maintained, first at USCIS, and
later by transfer to the National Archives and Records
Administration (NARA). Records Schedule Number:
NI-556_08-11.
U.S. Immigration Records and Identity Services
Directorate (IRIS) is responsible for ensuring its
Records Branch maintains retention schedules for all
records they are charged with safekeeping.

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

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.
USCIS may share information from Form N-445 with other DHS components,
as appropriate, particularly when the information may result in
administrative and/or criminal proceedings.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
USCIS may share information contained on Form N-445 with other federal
agencies, state/local partners, international partners, or non-governmental
entities as appropriate, particularly information that may result in criminal
proceedings.
☐ 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:

Catherine Shorten

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

October 6, 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.)

October 17, 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.
USCIS uses the N-445 to notify applicants to appear (on a specific date and time) at a
naturalization ceremony for administration of the oath of allegiance. USCIS stores the N445 in CLAIMS 4 and USCIS ELIS, depending on how the N-400 was filed. USCIS ultimately
stores the forms in the A-file (paper or electronic). USCIS recommends coverage under the
CLAIMS 4 PIA and USCIS ELIS PIAs which cover the processing of the form N-445. The BIS
and A-file SORN also allows for the collection and storage of the N-445.

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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

1152049
October 27, 2017
October 27, 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 October 18, 2017
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
New e(3) statement is required.
Statement:
PN submitted with this PTA is adequate
PTA:
CLAIMS 4 PTA is adequate
PIA:
PIA Appendix update required
If covered by existing PIA, 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

DHS/USCIS/PIA-015 Computer Linked Application Information
Management System (CLAIMS 4) and subsequent Updates;
Update to Appendix of DHS/USCIS/PIA-056 USCIS Electronic
Immigration System
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, September 18, 2017, 82 FR 43556;
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 to document the use of Form N-445. Form N-445 is used by
persons who will become U.S. citizens upon taking the oath of allegiance in a formal public
ceremony. Form N-445 was in use first by legacy Immigration and Naturalization Service,
and continues to be used by USCIS to notify applicants to appear for a naturalization oath
ceremony and to determine continued eligibility for naturalization.
The DHS Privacy Office (PRIV) agrees with USCIS that Form N-445 is a privacy sensitive
information collection that requires PIA coverage because it collects PII from members of
the public. DHS/USCIS/PIA-016(a) CLAIMS 4 assesses the privacy risks of the collection,
use, and storage of PII in the naturalization process, to include information collected for the
citizenship oath ceremony. DHS/USCIS/PIA-056-ELIS will cover the storage of scanned N445 forms in its system, but requires an appendix update to include the storage of Form N445 to provide transparency to the public.
PRIV finds that SORN coverage is required because Form N-445 collects PII that is
retrieved by unique identifier. The DHS/USCIS/ICE/CBP-001 Alien File SORN covers the
collection, use, and maintenance of PII throughout the immigration process, to include the
citizenship oath ceremony. The DHS/USCIS-007 BIS SORN covers the use of applicant PII
for the determination of “good moral character” that may not be reflected in the A-file.
This PTA will expire in one year.

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