Privacy Threshold Analyis

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-131A

Form Title:

Form I-131A Application for Travel Document (Carrier Documentation)

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

International Operations

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title: Form I-131A Application for Travel Document (Carrier Documentation)
OMB Control
OMB No. 1615-0135
Number:
Collection status: Extension

Name:
Office:
Phone:

Name:

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

August 31, 2018
March 23, 2015

PROJECT OR PROGRAM MANAGER
Jessica Leigh
International Operations
Title:
Adjudications Officer
202-272-8116
Email:
[email protected]
v
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:

USCIS, Office of Policy and
Strategy

Title:

Management and Program
Analyst

Phone:

202-272-0993

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.
2018 EXTENSION
USCIS is submitting this PTA to coincide with the Form I-131A (OMB No. 1615-0020)
Paperwork Reduction Act (PRA) extension. As part of this PTA package, there were no
changes to the form information collection.
Form I-131A , Application for Travel Document
USCIS created Form I-131A to allow individuals to apply for Carrier Documentation
(Transportation Letter or Boarding Foil) at a U.S. Embassy or U.S. Consulate. The form may
be submitted by an individual to the nearest U.S. Embassy or U.S. Consulate. Depending
on the location, this may involve filing the application with either USCIS or the Department
of State.
Carrier Documentation may be issued to a lawful permanent resident or conditional
permanent resident of the United States who is not in possession of a valid, unexpired
Permanent Resident Card, Reentry Permit, or other evidence of lawful permanent resident
status (e.g., the card has expired, or was lost, stolen, destroyed/mutilated), so that the
individual may be allowed to board a vessel or aircraft, travel to the United States, and
present themselves at a U.S. port-of-entry for inspection as a returning lawful permanent
resident. Carrier Documentation is only used overseas and is not filed domestically. The
creation of the Carrier Documentation created a mechanism for USCIS to collect a fee for
this service. The fee is used to cover processing costs.
Issuance of Carrier Documentation does not remove the requirement to replace or renew
a Permanent Resident Card. To apply for a replacement or renewal of a Permanent
Resident Card, the individual must file Form I-90, Application to Replace Permanent
Resident Card, with USCIS.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Issuance of Carrier Documentation is discretionary and may not be appealed. Carrier
Documentation does not guarantee admission or other form of entry into the United
States, and U.S. Customs and Boarder Protection (CBP) will carry out all required
inspection procedures upon arrival at a U.S. port-of-entry. Furthermore, DHS may revoke
or terminate Carrier Documentation at any time.
Relevant Information Technology
USCIS uses CAMINO to process the I-131A, and the information is entered into CLAIMS 3.
At the Department of State, the I-131A will be processed in the Non-Immigrant Visa
Operating System in CCD.
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 form, and the associated evidence, is collected
pursuant to Sections 101; 211; 212(d)(5); 264; and 273 of the Immigration and
Nationality Act, as amended, as well as 8 CFR 211.1(a) and (b); 8 CFR 212.5(f); 8 CFR
264.1(c); 8 CFR 273.3.

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.)

☒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.)

☒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.
The form may be filled out by an interpreter or a
preparer that is not the applicant.

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.
Information about the applicant:
 Full Name


A-Number



Current and Mailing Address



Date of birth



Social Security number

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



USCIS Online Account Number (if any)



Country of birth



Country of citizenship or nationality



Gender



U.S. Departure Date



Date of Intended Travel to the United States



Reason for Application



Phone number



E-mail address



Signature



The application also requests information about whether the applicant has ever
filed a Form I-407, Abandonment of Lawful Permanent Resident Status, or ever
been issued Carrier Documentation.

Information collected about the representative and accredited representative includes:


Attorney State License Number



Attorney or Accredited Representative USCIS Online Account Number (if any)

Information collected about the form preparer includes:


Full Name



Business or Organization Name



Mailing Address



Phone Number



Fax Number



Email Address



Signature

Information collected about the interpreter includes:


Full Name



Business or Organization Name



Mailing Address



Phone Number



Email Address

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

 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.
☒Social Security number

☐DHS Electronic Data Interchange

☒ Alien Number (A-Number)

Personal Identifier (EDIPI)

☐Tax Identification Number

☐Social Media Handle/ID

☐Visa Number

☐Known Traveler Number

☐Passport Number

☐Trusted Traveler Number (Global

☐Bank Account, Credit Card, or other

Entry, Pre-Check, etc.)

financial account number
☒ Other. Please list:

☐Driver’s License Number
☐ Biometrics




USCIS Online Account Number (if
any)



Attorney State License Number



Attorney or Accredited
Representative USCIS ELIS Account
Number (if any)

g. List the specific authority to collect SSN or these other SPII elements.
The primary legal authority supporting the collection of information derives from 8
U.S.C. Section 1101; and 8 U.S.C. Section 1103 charges the DHS Secretary with the duty of
administering and enforcing all laws relating to the immigration and naturalization of
aliens.
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 A-number and SSN information collected within the Form I-131A application is used
to assist USCIS in enforcing the immigration laws of the United States by providing
timely and accurate information about persons who are subject to those laws. USCIS
personnel conduct background security checks on applicants for the purpose of
determining whether the applicant has established eligibility for the benefit requested.
The A-number and SSN are especially useful and provides significant information to
verify an applicant’s identity and his/her claim to eligibility: providing a critical tool for
more accurate and appropriate adjudication determinations for USCIS and the applicant.
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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.

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.
USCIS provides a Privacy Notice on the form
instruction. Additionally, the form must be
certified and signed by the applicant even if they
use an attorney/preparer to fill out the form.
☐No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒Paper. Please describe.
the original,
The forms are currently held in an overseas T-file
completed IC/forms?
and then interfiled with the A-file; however, IO
and IVCS are rolling out an I-131A Document
Repository which will house all adjudicated forms
electronically.
☒Electronic. Please describe the IT system that will
store the data from the form.
If yes, please list:
While the form does not actually connect to any
systems, the information from the form is input
into CLAIMS 3, CCD and/or CAMINO.
☒Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
The forms are currently held in an overseas T-file
and then interfiled with the A-file; however, IO
and IVCS are rolling out an I-131A Document
Repository which will house all adjudicated forms
electronically.
b. If electronic, how
does DHS input the
responses into the IT
system?
Privacy Threshold Analysis – IC/Form

☒Manually (data elements manually entered). Please
describe.

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

While the form does not actually connect to any
systems, the information from the form is input
manually into CLAIMS 3, CCD and/or CAMINO.
☐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.

☒By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
The information submitted on the form is
retrieved by the USCIS Online Account Number
and/or the applicant’s A-number.
☐By a non-personal identifier. Please describe.
Click here to enter text.
DAA-0566-2016-0022 covers adjudicative decision of
Form I-131A. Destroyed 2 year(s) to 6 year(s) after the
date of the adjudicative decision.
N1-566-12-06 covers CAMINO records. Data is destroyed
25 years after the individual’s latest case completion
date.
DAA-0566-2016-0009 covers CLAIMS 3 records. Data is
destroyed 50 years after the last completed action.
N1-566-08-11 covers A-File records as permanent value.

e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?

A-files and the I-131A Document Repository are retained
permanently. After 25 years of existence, CAMINO will be
checked to purge any records that have no completed
action.

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

Data stored in CLAIMS 3 will follow the approved
retention schedule for CLAIMS 3.
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.
☒Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
The I-131A application is filed overseas with either USCIS or with the Department
of State where USCIS is not co-located. The information from the form is input into
CLAIMS 3, CCD and/or CAMINO. Ultimately, the USCIS adjudicated forms will be
held in an electronic repository that is maintained by IVCS.

☐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:

Jenny Hoots

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

April 9, 2018

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.)

April 10, 2018
☒ 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.
Form I-131A allows individuals to apply for a Carrier Evidence Document, which only
allows them to board a commercial carrier for travel back to the United States. The USCIS
Office of Privacy recommendation is to designate Form I-131A as privacy sensitive with
coverage under:
Privacy Impact Assessment
 DHS/USCIS/PIA-051 Case and Activity Management for International Operations
(CAMINO)
 DHS/USCIS/PIA-016(a) CLAIMS 3 PIA and Associated Systems
 DOS Consular Consolidated Database (CCD) PIA
System of Records Notice
 DHS-USCIS-001 – A-File SORN
 DHS-USCIS-007 - Benefits Information System SORN
 STATE-05-Overseas Citizens Services Records SORN

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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

1161455
April 19, 2018
April 19, 2019

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 April 16, 2018
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Statement:
Current Privacy Act Statement is adequate
PTA:
Current CLAIMS 3 PTA and CAMINO PTA are adequate
PIA:
PIA Appendix update required

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

If a PIA update is required, please list: Update to DHS/USCIS/PIA-016a
Computer Linked Application Information Management System
(CLAIMS 3) and Associated Systems
Update to DHS/USCIS/PIA-051 Case and Activity Management for
International Operations (CAMINO)
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 compliance documentation for Form I-131A,
Application for Travel Document (Carrier Documentation). Carrier Documentation may be
issued to a LPR or conditional permanent resident whose immigration documentation has
expired, was lost, stolen, or destroyed. Form I-131A allows the individual to board a vessel
or aircraft, travel to the United States, and present themselves at a port of entry. There
have been no changes to the form since the last PTA adjudication.
The DHS Privacy Office (PRIV) agrees with USCIS that Form I-131A is a privacy sensitive
information collection, requiring PIA coverage, because it collects PII from members of the
public. PRIV finds that an update to the appendix of DHS/USCIS/PIA-016(a) CLAIMS 3 and
DHS/USCIS/PIA-051 CAMINO are necessary to provide transparency that the form is
processed in their respective systems.
PRIV concludes that SORN coverage is necessary because Form I-131A information is later
retrieved by a unique identifier. PRIV finds that the DHS/USCIS/ICE/CBP-001 A-File SORN
covers the collection of information on the form for the administration of the immigration
system. DHS/USCIS-007 BIS SORN covers the adjudicative data collected by USCIS that may
not appear in the A-File.
This Form contemplates information sharing with the Department of State. PRIV finds that
such sharing is compatible under routine use O of the A-File SORN and routine use I of the
BIS SORN to assist with the processing of immigration benefits.
PRIV finds that a Privacy Act Statement is required because Form I-131A collects
information from US Persons and non US Persons that is then entered into a system of
records. PRIV concludes that the current Privacy Act Statement provides the public
adequate notice.
This PTA will expire in one year due to its reliance upon two PIA appendix updates.
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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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