Privacy Threshold Assessment

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.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 1 of 13

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 Title:
Component:

N-426
Request for Certification of Military or Naval Service
U.S. Citizenship and
Office:
Field Operations
Immigration Services
Directorate
(USCIS)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form N-426, Request for Certification of Military or Naval Service
OMB Control
1615-0053
OMB Expiration
July 31, 2019
Number:
Date:
Collection status:
Revision
Date of last PTA (if
December 1, 2016
applicable):

Name:
Office:
Phone:

Name:

PROJECT OR PROGRAM MANAGER
Lorra Wilkinson
Field Operations
Title:
Adjudications Officer
Directorate
(206) 920-4950
Email:
[email protected]
s.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Kerstin Jager

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 2 of 13

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

Office:
Phone:

Office of Policy and
Strategy
(202) 213-4211

Title:

Management and Program
Analyst
Email:
[email protected]
ov
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 Revision
Form N-426, Request for Certification of Military or Naval Service, is set to expire on July
31, 2019. USCIS is revising the Form N-426 to collect additional data elements. Recent
changes in DoD policy required changes to USCIS policy and procedures. These changes
require amending Form N-426 to gather additional needed fields to ensure compliance
with the policy changes. Since the last PTA adjudication, Form N-426 is now collecting
the requestor’s country of citizenship, country of naturalization, province for place of
enlistment, province for residence during enlistment, province for place of reenlistment,
and province for residence during reenlistment. Form N-426 is also collecting additional
information about the Certifying Official – branch of service, component, rank, and work
telephone number.
Form N-426, Request for Certification of Military or Naval Service
Pursuant to Sections 328 and 329 of Immigration and Nationality Act (INA), USCIS must
defer to the determination of the Department of Defense (DoD) holding the military
service records when reviewing an applicant for naturalization’s affirmed honorable
service in the United States Military.
Persons who are serving or have served under specified conditions in the Armed Forces
of the United States are granted certain exemptions from the general requirements for
naturalization. To establish eligibility, the law requires the departments with custody of

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 3 of 13

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

the service records to certify when the service member served and whether each
separation from the service was under honorable conditions.
The purpose of Form N-426 is to maintain a uniform, streamlined mechanism for DoD to
certify an applicant’s characterization of military or naval service. The applicant submits
Form N-426 to the appropriate branch of the U.S. military service in which he or she is
currently serving or had served for certification of military service. Proper completion of
this form by the applicant and certifying official serve as an authenticated certification of
military service.
Current or former members of the U.S. Armed Forces who are applying for naturalization
under section 328 or 329 of the INA submits the following with Form N-426:
1. Form N-400, Application for Naturalization, and
2. Copy of Form DD Form 214, Certificate of Release of Discharge from Active Duty, or
NGB Form 22, National Guard Report of Separation and Records of Service.
Relevant IT system
Receipt of Form N-426 is noted in CLAIMS 4. No data (other than the notation of receipt)
from the Form N-426 is stored in CLAIMS 4. The form is stored in the applicant’s 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.
Sections 328 and 329 of the INA and Title 8 of Code of Federal Regulations (8 CFR) Parts
328 and 329.

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

☒ Yes
☐No
☒ Members of the public
☒ U.S. citizens or lawful permanent
residents

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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 4 of 13

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

collect information?
(Check all that apply.)

☒ Non-U.S. Persons.
☒ DHS Employees
Please note that DoD enlists members of the
United States Coast Guard. Though, these
individuals serve under DoD when training
and while deployed; they are DHS employees
the majority of the time.
☐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.).
A preparer may fill the Form N-426 out if they
have also submitted a Form G-28 with the
Form N-400.
☐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.
Certain Service Members, civilian employees,
or contractors of the Department of Defense
may act as conduits and submit the form in
response to a request for evidence (RFE) by
USCIS on behalf of the Service Member and
with the expressed permission and consent of
the Service Member.
Please note that DoD enlists members of the
United States Coast Guard. Though, these

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 5 of 13

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

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

individuals serve under DoD when training and
while deployed; they are DHS employees the
majority of the time. Some may be enlisted as
Lawful Permanent Residents require
naturalization.
☒ 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.
There are no new data elements being collected as a result of the 2018 revision of Form
N-426. However, there were data elements that were not accounted for on the previous
PTA adjudication. The list below contains a full inventory of PII collected by type of
individual.
Information about the Requestor:
















Alien Number
Military Service Number
Full name
Other names used
Social Security number
USCIS Online Account Number
Date of birth
Place of birth (country and city)
Country of citizenship
Country of nationality
Physical address
Information about place of enlistment (country, city, state, province)
Information about residence when requestor enlisted (country, city, state,
province)
If applicant reenlisted
Information about place of reenlistment (country, city, state, province)

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 6 of 13

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








Information about residence when requestor reenlisted (country, city, state,
province)
Periods of military service (branch of service, service start date, service end date,
type of service)
Daytime phone number
Mobile phone number
Email address
Signature

Information about the Certifying Official:
 Full name
 Rank
 Title
 Branch of Service
 Component
 Work phone number
 Military email address
 Signature
The Certifying Official must indicate whether the requestor served honorably or is
currently serving honorably for each period of military service the requester served. The
Certifying Official must also indicate if the requestor separated and, if so, whether it was
an honorable discharge, other discharge, or a discharge on account of alienage.
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: Military Service
Number, USCIS Online Account Number
g. List the specific authority to collect SSN or these other SPII elements.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 7 of 13

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

INA 264(f) (8 U.S.C. 1304(f)) provides the Secretary of Homeland Security with the
specific authority to collect SSNs of those applying for immigration benefits. USCIS
collects the SSN to facilitate the adjudication of the application. The SSN is used to
establish and corroborate the requestor’s identity.
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.
DoD does not utilize A-Numbers when maintaining records of alien service members.
USCIS must have a standardized approach for verifying an applicant’s Characterization of
Service. Without the information provided in the Form N-426, the service member would
have little to no ability to demonstrate eligibility to naturalize pursuant to honorable
United States military service. Information collected will be used to verify the
requestor’s Characterization of Service as required under Sections 328 and 329 of the
INA. Form N-426, and the information collected by it, allows the applicant a
straightforward approach to demonstrating eligibility for naturalization.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
Individuals completing the form are notified via a
time of collection by
Privacy Notice in the instructions for the Form NDHS (Does the records
426.
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,
Form N-426 will be stored in the individual’s Acompleted IC/forms?
File.
☐Electronic. Please describe the IT system that will
store the data from the form.
Click here to enter text.
☐Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 8 of 13

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?

☐Manually (data elements manually entered). Please
describe.
Click here to enter text.
☐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.
Information can be retrieved by name, date of
birth, A-Number, Receipt number, or combination
of the above data elements.
☐By a non-personal identifier. Please describe.
Click here to enter text.
Form N-426: DAA-0566-2016-0017 covers the
adjudicative decision of Form N-426. Records are
retained for 100 year(s) after the requestor’s date of
birth.
A-File: N1-566-08-11 covers A-File records as
permanent value.
The system owner is responsible for ensuring the records
are deleted in accordance with a retention schedule.

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

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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 9 of 13

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

☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
At times, the Form N-426 may be shared with our law enforcement partners within
DoD via appropriate channels and “need to know” standards.
☐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.
PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Amanda Hoffmaster

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

May 14, 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.)

May 31, 2018
☐Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
The Privacy Notice is in draft and will be
reviewed and approved by USCIS’ OCC.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 10 of 13

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

The USCIS Office of Privacy recommends designating Form N-426 as a privacy sensitive
form with coverage under the following:
PIA


DHS/USCIS/PIA-015 Computer Linked Application Information Management
System (CLAIMS 4) (and subsequent updates), which covers the processing of N-400
Applications for Naturalization and supplemental documents such as the N-426.

SORN
 DHS-USCIS-001 Alien File, Index, and National File Tracking System, which covers
the physical and electronic immigration files, including A-Files and Receipt Files.
 DHS/USCIS-007 Benefits Information System, which covers the collection, use, and
storage of data elements USCIS collects about benefit requestors, beneficiaries, legal
representatives, interpreters, and preparers.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 11 of 13

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

1164078
June 25, 2018
June 25, 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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 12 of 13

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

PIA:

SORN:

System covered by existing PIA
If covered by existing PIA, please list: DHS/USCIS/PIA-015 Computer
Linked Application Information Management System (CLAIMS 4)
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/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

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.
USCIS is submitting this PTA as part of the PRA renewal process to discuss Form N426, Request for Certification of Military or Naval Service. This form is used to
provide a uniform method for the Department of Defense to certify an individual’s
characterization of their military or naval service. USCIS is required to defer to the
determination of the Department of Defense when reviewing an applicant for
naturalization’s affirmed service in the U.S. military.
An applicant submits the form to the appropriate branch of the military service in
which he or she served or is serving. The form contains PII and SPII about the
applicant, which is used to verify the applicant’s service. The form also collects work
contact information about a military certifying official.
The DHS Privacy Office agrees that this form is privacy sensitive, requiring PIA
coverage. Coverage is provided by DHS/USCIS/PIA-015 CLAIMS 4, which covers the
processing of naturalization documents and associated supplemental documents.
Receipt of Form N-426 is noted in CLAIMS 4. SORN coverage is also required, as
information is retrieved by personal identifier. Coverage is provided by DHS/USCIS001 Alien File, Index and National File Tracking System, which covers the physical
and electronic Alien File, in which Form N-426 is stored. Coverage is also provided
by DHS/USCIS-007 Benefits Information System, which covers data elements about
benefit requestors, beneficiaries, preparers, and interpreters.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 13 of 13