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:

Form I-907

Form Title:
Component:

Request for Premium Processing Service

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

SCOPs

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form I-907
OMB Control
Number:
Collection status:
Name:
Office:
Phone:
Name:

1615-0048
Extension

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

Click here to enter a
date.
July 2, 2014

PROJECT OR PROGRAM MANAGER
Yanina Shteynberg
SCOPS-EPIC
Title:
Adjudications Officer-Policy
202-272-8177
Email:
[email protected]
hs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Evadne Hagigal

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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
Title:
Management and Program
Division
Analyst
Click here to enter text.
Email:
Click here to enter text.
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.
This PTA is being updated to document the form extension. The purpose of the
Form I-907 is to request Premium Processing service for certain petitions or
applications which are currently designated as eligible for premium processing by
USCIS.
Currently, USCIS designated certain employment based immigrant and
nonimmigrant visa petitions as eligible for the Premium Processing service.
Petitioners may use Form I-907 to request expedited processing of certain
employment-based visa categories. By filing the Form I-907 with the appropriate
fee, the petitioner requests that his or her visa petition is processed within 15
calendar days. The processing time is met if USCIS issues an approval, a request for
evidence, notice of intent to deny, or a denial notice within 15 calendar days of
receipt or if the case is referred for investigation of suspected fraud or
misrepresentation. Once USCIS receives a response to the request for evidence or
notice of intent to deny, USCIS will guarantee 15-calendar-day processing from the
date the response was received.
The Premium Processing is available for the Form I-129, Petition for a
Nonimmigrant Worker, and Form I-140, Immigrant Petition for Alien Worker. Not
all visa classifications within these forms are eligible for Premium Processing
Service. For instance, the R-1 classification is only eligible after a successful on-site
inspection at the location of employment.
Petitioner, applicant, or the attorney or accredited representative, may request
Premium Processing service with the eligible petition or application, or after the
eligible petition/application was already filed but before a final decision has been
rendered. By filling out Form I-907, the petitioner, applicant, attorney or
representative provides information about him or herself, the petitioning business
(if not the filer of Form I-907) and the beneficiary.

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

Service Center Operations (SCOPS) is the responsible Program Office. SCOPS
oversees the operations of the four regional service centers which process
applications for immigration benefits based on the applicant’s employment in the
United States.
The form I-907 relates to the USCIS mission by improving the efficiency and
customer service of its delivery of immigration benefits to the public.
The previous form I-907 PTA, completed in July 2014, has expired. USCIS is
resubmitting this PTA as part of the PRA renewal process. No substantive changes
have been made to the form since the last PTA.
Relevant IT System
The form I-907 is processed in the Computer Linked Application Management
System (CLAIMS 3) and stored in the subjects A-file.
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.
8 U.S.C. sections 1103 and 1356 authorizes USCIS to collect the information and the
associated evidence for this benefit application.

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.
Click here to enter text.

☒ 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 categories of individuals for whom information is collected are members of
the public who are statutorily eligible either as petitioners, applicants,
beneficiaries, or attorneys or accredited representatives (e.g., interpreter and
preparers).
PII includes: A-number, Full name, address, company or organization’s IRS tax ID
number, company or organization name, company point of contact, name,
telephone number(s) , email address, and fax number, mailing address, USCIS ELIS
number, and signature.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ Social Security number
☒ Alien Number (A-Number)
☒ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
The authority to collect information in this form is set forth in the Immigration and
Nationality Act, 8 U.S.C. §§ 1103, 1356 and in the implementing regulations found
in volume 8 of the Code of Federal Regulations (CFR).
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 PII is collected in order to help identify the primary Form I129 or I140 that
was filed by the same petitioner or applicant and to which the I-907 is a
supplemental request. It also enables USCIS to properly retrieve information about
the petitioner or the beneficiary, if the PII information is included.
i. Are individuals
☒ Yes.
provided notice at the
Yes, through a Privacy Act Statement. The Statement
time of collection by
is being updated and converted to a notice as a result
DHS (Does the records
of this update.
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,
Beneficiary’s Alien File
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
CLAIMS 3

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

b. If electronic, how
does DHS input the
responses into the IT
system?
c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

d. What is the records
retention
schedule(s)? Include
the records schedule
number.

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.
Enterprise Document Management System (EDMS)

☒ Manually (data elements manually entered). Please
describe.
USCIS may scan the I-907 into its electronic
databases when it digitized the Alien file.
☐ Automatically. Please describe.
Click here to enter text.

☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
The user can use the TAX ID, Alien Number,
receipt numbers listed on the Form I-907, name,
or other combined data elements.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
CLAIMS 3: CLAIMS 3 will delete and destroy records 50
years from the date of the last completed action.
USCIS is working with NARA to update and consolidate
the current retention schedules N1-563-04-03 and N1566-08-12.

A-File: A-File records are permanent records in both
electronic and paper form. USCIS transfers A-Files to the
custody of NARA 100 years after the individual's date of
birth [N1-566-08-11]
The system owner is responsible for ensuring the records
are 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.
Click here to enter text.
☒ 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.)

Catherine Shorten
September 18, 2017
September 20, 2017

☒ Yes. Please include it with this PTA
submission. We have an approved PAS on file.
USCIS is working to update and convert it to a
Privacy Notice.
☐ 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 recommends coverage under the following PIAs and SORNs:
• DHS/USCIS/PIA-016(a) CLAIMS 3 and Associated Systems
• DHS-USCIS-007 - Benefits Information System
• DHS/USCIS/ICE/CBP-001 – Alien File, Index, and National File Tracking System
of Records

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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

1150585
September 22, 2017
September 22, 2020

DESIGNATION

Privacy Sensitive IC or
Form:
Determination:

Yes If “no” PTA adjudication is complete.
☐ 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 not received this ICR/Form.
Date IC/Form Approved
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
e(3) statement update is required.
Statement:
Privacy Statement must be updated to a Privacy Notice.
PTA:
CLAIMS 3 PTA is adequate
PIA:
System covered by existing PIA
If covered by existing PIA, please list:
DHS/USCIS/PIA-061 Benefit Request Intake Process
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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-016(a) Computer Linked Application Information
Management System (CLAIMS 3) and Associated Systems
DHS/USCIS/PIA-003(b) Integrated Digitization Document Management
Program
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 renew expiring compliance documentation for Form I-907.
The purpose of the Form I-907 is to request Premium Processing service for certain
petitions which are currently designated as eligible for premium processing by USCIS.
There were no substantive changes to the form since the previous PTA adjudication.

The DHS Privacy Office (PRIV) finds that Form I-907 is a privacy sensitive information
collection that requires PIA coverage because it collects PII from members of the public.
PRIV concludes that DHS/USCIS/PIA-061 Benefit Intake Process covers the collection and
processing of the initial Form I-907 while DHS/USCIS/PIA-016(a) CLAIMS 3 covers the
form’s entry, use, and storage in that IT system. DHS/USCIS/PIA-003(b) IDDMP is
necessary to provide coverage for the scanning of paper Form I-907 for entry into EDMS.

PRIV agrees with USCIS that Form I-907 requires SORN coverage because PII it collects is
stored in a system that retrieves information by a unique identifier. PRIV finds that the
DHS/USCIS/ICE/CBP-001 Alien File SORN, which covers the collection, use, and
maintenance of information from applicants as they move through the immigration
process; and DHS/USCIS BIS SORN, which covers all information collected in the
immigration benefit adjudication process not contained in the A-File, provides adequate
coverage for Form I-907.

PRIV finds that a Privacy Notice is required because form I-907 collects information from
non-US Persons that is entered into a system of records. USCIS must update its privacy act
statement to a privacy notice and eliminate reference to DHS-USCIS-015 Electronic
Immigration System-2 in its routine uses. USCIS must also delete reference to 8 U.S.C.
sections 1158, 1225, and 1228 and Title II of Public Law 105-100 as authorities of
collection and replace it with 286(u) of the Immigration and Nationality Act (8 U.S.C.
section 1356).

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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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