Forms 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:

OMB Control # 1653-0053

Form Title:

Allegation of Counterfeiting and Intellectual Piracy

Component:

Immigration and
Customs Enforcement
(ICE)

Office:

Homeland Security
Investigations (HSI)National IPR Center

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Allegation of Counterfeiting and Intellectual Piracy
Collection Title:
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:

1653-0053
Revision

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

October 31, 2018
Click here to enter
a date.

PROJECT OR PROGRAM MANAGER
Kevin Cousino
HSI IPR Center
Title:
Section Chief
703-603-3894
Email:
[email protected]
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Scott Elmore
ICE OCIO
Title:
Forms Manager

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

Phone:

202-732-2601
Email:
[email protected]
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 is an updated PTA; the reason for submission is to update ICE Form 73-048
(Allegation of Counterfeiting and Intellectual Piracy).
The U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations
(HSI)-led National Intellectual Property Rights Coordination Center (IPR Center) brings
together 23 partner agencies to effectively leverage the resources, skills, and authorities of
each in order to provide a comprehensive and coordinated response to intellectual property
rights crimes. The IPR Center works with copyright owners, trade associations and both
foreign and domestic law enforcement agencies. It accepts allegations concerning IPR
violations from individuals and entities in both the public and private sector and has a
website where allegations may be uploaded. Further information about the IPR Center is
available at http://www.iprcenter.gov/.
The IPR Center modernized and automated its operations to gain efficiencies and improve
effectiveness. One of the ways to accomplish this is through a system that automates the
intake, development, deconfliction, and referral of investigative lead information intended
for the purpose of initiating or resolving criminal and/or civil investigations and support
actions involving IPR violations.
In coordination with its partner agencies, the IPR Center developed protocols for lead
development and deconfliction. These come into play when complaints are received, either
from the IPR Center’s website or through referrals or direct reports to a Center member.
Complaints are circulated among participating members of the IPR Center to determine if
any agency is already investigating the matter. If this process reveals no active
investigations or other pertinent information, IPR Center partners conduct a review of the
information to determine if it is sufficient to justify a criminal investigation. If so, a partner
agency will be selected to pursue the matter, based on the merits and origin of the lead, the
commodity involved, and a previously-agreed-to rotation schedule.
To facilitate the lead development and deconfliction process, the IPR Center updated the
form it uses for complaint intake to add a number of data fields that provide more robust
information about the allegation of a potential intellectual property crime. Personal
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

identifiers of the complainant are now solicited along with information about witnesses and
victims as well as alleged violators, if available, and is stored in an ICE approved
database/spreadsheet. A Privacy Act notice appears on the form.
HSI uses ICE Form 73-048, “Allegation of Counterfeiting and Intellectual Piracy Form” to
allow individuals to report suspected violations of intellectual property rights. Individuals
filling out this form provide information to ICE-HSI about individuals, businesses, and/or
organizations that have violated counterfeiting and intellectual property rights laws. The
information is collected from anyone who wishes to report a violation using the referral
form available at https://www.iprcenter.gov. The specific information collected on the form
is outlined in Question 2e (below). All information provided on the form is voluntary.

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: 6 U.S.C. § 202; 8 U.S.C. § 1103; 8 U.S.C. § 1360; 31 CFR Chapter X, 5 U.S.C. §
552a; 5 U.S.C. § 301; 44 U.S.C. § 3101; Homeland Security Act of 2002, as amended,
Pub. L. No. 107-296, 116 Stat. 2135 (2002); Immigration and Nationality Act of 1952,
as amended, U.S. Code Title 8; DHS Delegation No. 7030.2, Delegation of Authority to
the Assistant Secretary of U.S Immigration and Customs Enforcement; ICE
Delegation No. 0001, Delegation of Authority to the Directors, Detention and
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Removal and Investigations, and to Field Office Directors, Special Agents in Charge
and Certain Other Officers of the Bureau of Immigration and Customs Enforcement;
and 8 C.F.R. § 2.1, Authority of the Secretary of Homeland Security authorize ICE to
collect the information requested in this web form.

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

☒ Yes
☐No

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

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

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. Please describe.

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

Anyone can voluntarily complete and submit
the form.
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: People click the “Report IP Theft”
button at www.iprcenter.gov/

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.
PII on the ICE Form 73-048 includes:
Section 1: Information about the Individual/Business that violated intellectual property rights:
• Business Name;
• First Name;
• Middle Initial;
• Last Name;
• Gender;
• Address (full);
• Country;
• Email address;
• Phone number;
• Email address;
• Website;
• IP Address;
• Social Media site;
• Social Media user account;
Section 2: Other identifiers about the Individual/Business that violated intellectual property
rights:
• Website;
• IP Address;
• Social Media site;
• Social Media user account;
Section 6: Additional Information (if applicable, indicate the means of contact with the
individual/business that violated the intellectual property rights).
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Section 7: Witness or Victim 1:
• First Name;
• Middle Initial;
• Last Name;
• Address (full);
• Country;
• Phone number;
• Email address;
• Website;
Section 8: Witness or Victim 2:
• First Name;
• Middle Initial;
• Last Name;
• Address (full);
• Country;
• Phone number;
• Email address;
• Website;
Section 9: Organization 1:
• Organization Name;
• Contact Name;
• Phone number;
• Email address;
Section 10: Organization 2:
• Organization Name;
• Contact Name;
• Phone number;
• Email address;
Section 11: Contact information about the individual submitting the complaint (if the
complainant wishes to identify him/herself):
• First Name;
• Middle Initial;
• Last Name;
• Business Name;
• 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

Section 12: For Industry Use
Entities (Persons or Businesses) engaged in production, transportation, distribution or
sale of counterfeit goods, foreign or domestic (Manufacturers, Shippers, Trading
Companies, Freight Forwarders, Importers, Brokers, Individuals, etc.), or information
regarding specific shipments.
• Entity Name
• Entity Address
• Entity Phone Number
• Entity URL (web address)
• Entity IP (internet protocol)
• Foreign Places of Receipt
• Foreign Ports of Lading
• Domestic Ports of Arrival or Entry
• Cargo Descriptions Used
• Container Number (s)
Entities subject to Cease & Desist letters, Suits, Arrests, Prosecutions, etc., foreign or
domestic.
• Entity Name
• Entity Address
• Entity Phone Number
• Entity URL (web address)
• Entity IP (internet protocol)
Seizures executed overseas by foreign Customs or Law Enforcement and the
shipping or manifest information associated with those seizures.
• Country
• Port
• Importer Name
• Importer Phone Number
• Importer Address
• Exporter Name
• Exporter Phone 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

• Exporter Address
• Freight Forwarder Name
• Freight Forwarder Address
• Freight Forwarder Phone Number
• Counterfeit Goods Seized
• Cargo Description(s) Used
• Weight
• Quantity
• Destination Port (if different than detection Port)
• Container Number(s)
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. No, the form does not
☐ 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:
g. List the specific authority to collect SSN or these other SPII elements.
ICE may collect and maintain records about individuals, including Social Media
Handle/ID pursuant to the following authorities:


Homeland Security Act of 2002, as amended, Pub. L. No. 107-296, 116 Stat.
2135 (2002);



DHS Delegation No. 7030.2, Delegation of Authority to the Assistant
Secretary of U.S Immigration and Customs Enforcement;



19 U.S.C. § 1589a, Enforcement authority of customs officers;



8 U.S.C. § 1357, Powers of immigration officers and employees;

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



Homeland Security Act of 2002, as amended, Pub. L. No. 107-296, 116 Stat.
2135 (2002);



Immigration and Nationality Act of 1952, as amended, U.S. Code Title 8;



DHS Delegation No. 7030.2, Delegation of Authority to the Assistant
Secretary of U.S Immigration and Customs Enforcement;



ICE Delegation No. 0001, Delegation of Authority to the Directors, Detention
and Removal and Investigations, and to Field Office Directors, Special
Agents in Charge and Certain Other Officers of the Bureau of Immigration
and Customs Enforcement;

 8 C.F.R. § 2.1, Authority of the Secretary of Homeland Security.
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.
Not Applicable
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.
Click here to enter text.
☒ No.
The Form is filled out by 3rd party in most
instances.

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.
The original ICE Form 73-048 is stored on the
ICE network by HSI special agents assigned to
the National Cyber-Forensics and Training
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Alliance (NCFTA) in Pittsburgh, PA. Pertinent
data (i.e. Names, Businesses, email address, IP
addresses, phone numbers) are indexed on a
spreadsheet (HSI network) as well as indexed
on a spreadsheet maintained by the NCFTA on
their database.
☐Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
HSI special agents assigned to the NCFTA
manually transfer the pertinent data from the
ICE Form 73-048 (i.e. Names, Businesses, email
address, IP addresses, phone numbers) to the
spreadsheets
☐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?

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Information on this form may be retrieved by the
following identifiers, if provided on the form: name,
internet protocol (IP) address, email address,
mailing address, and phone number.
☐By a non-personal identifier. Please describe.

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

Click here to enter text.
Deconfliction records are currently on a pending
schedule (Reports and Informational Materials
DAA-0567-2016-0004). We are making updates to

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 records schedule
number.

the schedule, until it has been approved by the
National Archives and Records Administration
please treat these records as permanent.
The ICE Form 8-002, Records Disposition Form is
e. How do you ensure
completed and submitted to HSI/ICE Records for
that records are
disposed of or deleted destruction approval. Once the records receive final
approval to be destroyed by ICE Records the form is
in accordance with
sent back to the requesting office. Once the records
the retention
are destroyed by the requesting office, the form is
returned to the ICE Records Division.
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
☒ Yes, information is shared with other DHS components or offices. Please describe.
This information is deconflicted/shared with the 23 IPR Center partners as
well as with the analysts assigned to the NCFTA (when they run open source
date base checks on the alleged target of the leads).
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
During the lead deconfliction process, the leads will be sent to the 23 IPR
Center Partners (besides HSI).
Domestic Law Enforcement Partners















Federal Bureau of Investigation (FBI)
U.S. Customs and Border Protection (CBP)
U.S. Food and Drug Administration, Office of Criminal Investigations (FDA OCI)
U.S. Postal Inspection Service (USPIS)
U.S. Naval Criminal Investigative Service (NCIS)
U.S. General Services Administration, Office of Inspector General (GSA OIG)
Defense Criminal Investigative Service (DCIS)
U.S. Army Criminal Investigation Command (Army CID)
Defense Logistics Agency, Office of Inspector General (DLA OIG)
U.S. Air Force Office of Special Investigations (AFOSI)
National Aeronautics and Space Administration, Office of Inspector General (NASA
OIG)
Nuclear Regulatory Commission
Federal Maritime Commission
U.S. Postal Service-Office of Inspector General

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

Regulatory Partners





U.S. Department of Commerce, International Trade Administration (DOC ITA)
U.S. Department of Commerce, U.S. Patent and Trademark Office (USPTO)
U.S. Consumer Product Safety Commission (CPSC)
U.S. Department of State, Office of International Intellectual Property Enforcement
(DOS)

International Partners





U.S. National Central Bureau (INTERPOL)
Government of Mexico Tax Administration Service (GOM SAT)
Royal Canadian Mounted Police (RCMP)
Europol

☐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:

Kevin Mullinix

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

September 27, 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.)

September 7, 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.
ICE is submitting this Forms-PTA to discuss ICE Form 73-048, “Allegation of
Counterfeiting and Intellectual Piracy Form” to allow individuals to report suspected
violations of intellectual property rights. Individuals filling out this form provide
information to ICE Homeland Security Investigations about individuals, businesses,
and/or organizations that have violated counterfeiting and intellectual property
rights laws. The form is also used for intake, development, deconfliction, and
referral of investigative lead information intended for the purpose of initiating or
resolving criminal and/or civil investigations and support actions involving IPR
violations.
PII is collected from individuals who complete ICE Form 73-048, “Allegation of
Counterfeiting and Intellectual Piracy Form” to report suspected violations of
intellectual property rights about an Individual/Business (biographic, and social
media identifiers). Individuals who complete ICE Form 73-048 may voluntarily
provide their name, and contact information.

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

PIA coverage is provided by the DHS-ICE-PIA-041 National Intellectual Property
Rights Coordination Center.
SORN coverage is provided by the DHS/ICE-009 External Investigations SORN, which
covers the collection of information to the extent that the information in the IPR
Center’s database is about individuals and is retrieved by their names or personal
identifiers.

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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:

Hannah Burgess

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

1169449
October 15, 2018
October 15, 2021

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:

Choose an item.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Choose an item.
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PIA:

System covered by existing PIA
If covered by existing PIA, please list: DHS/ICE/PIA-041 National
Intellectual Property Rights Coordination Center

SORN:

If a PIA update is required, please list: Click here to enter text.
System covered by existing SORN
If covered by existing SORN, please list: DHS/ICE-009 - External

Investigations January 5, 2010 75 FR 404
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
ICE is submitting this PTA to discuss Form 73-048, Allegations of Counterfeiting and
Intellectual Piracy Form, per the form renewal process. This form is used for allow individuals to
report suspected violations of intellectual property rights.
The form is accessible online, and is filled out by anyone wishing to report a violation. The form
collects PII from the individual filling out the form, as well as about individuals, businesses,
and/or organizations who they believe have violated counterfeiting and intellectual property
rights laws. The form collects information about witnesses and victims as well as alleged
violators. ICE uses the form for development, deconfliction, and referral of investigative lead
information.
The DHS Privacy Office agrees that this form is privacy sensitive, requiring PIA coverage.
Coverage is provided by DHS/ICE/PIA-041 National Intellectual Property Rights Coordination
Center. PRIV recommends that during the next update, this PIA be updated to expand and clarify
the information collected from both the individual submitting the report and other individuals
(witnesses, perpetrators, etc).
SORN coverage is also required, and is provided by DHS/ICE-009 External Investigations.
PRIV recommends that during the next update, this SORN be revised to include social media
information.

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