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.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 1 of 20

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

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

N-600

Form Title:

Application for Certificate of Citizenship

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

External Affairs
Directorate

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form N-600, Application for Certificate of Citizenship
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:

1615-0057
Revision

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

December 31, 2018
August 17, 2016

PROJECT OR PROGRAM MANAGER
Lorra Wilkinson
Office of Citizenship
Title:
Adjudications Officer
(206) 450-8859
Email:
[email protected]
s.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Kerstin Jager

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 2 of 20

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
USCIS submitting the Form N-600 PTA Update because USCIS plans to support the
electronic filing of Form N-600 in myUSCIS. This form is also undergoing the Paperwork
Reduction Act process. USCIS is updating the Form N-600 to provide clarifying language
in the instructions to align with the Immigration and Nationality Act (INA) and Title 8 of
the Code of Federal Regulations. No revisions were made to the information collection;
however, this PTA Update is accounting for the collection of identifying information that
was not captured in the previously adjudicated PTA.
Form N-600, Application for Certificate of Citizenship
Under Section 103 of the INA, USCIS is tasked with determining US citizenship of those
residing in the United States upon application.
Form N-600 is the form completed and submitted to obtain evidence of U.S. citizenship
demonstrating that the applicant derived citizenship. USCIS uses the information
collected on Form N-600 to determine if a Certificate of Citizenship can be issued to the
applicant. Citizenship law has changed over the years and different laws apply to
determine whether the applicant automatically became a U.S. citizen at birth, or after
birth but before they turned 18 years of age.
Form N-600 is used by respondents who are requesting a Certificate of Citizenship
because they were born outside the United States to a U.S. citizen parent. This form is
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 3 of 20

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

also used by applicants requesting a Certificate of Citizenship because they automatically
became a citizen of the United States after birth, but before they turn 18 years of age.
Form N-600 can also be filed by a parent or legal guardian on behalf of a minor child.
The form collects information that is necessary to determine eligibility for a Certificate of
Citizenship, which is further detailed in section 2.e. The information on Form N-600 is
supported with evidence submitted by the applicant. Adjudication of the application
depends on meeting the eligibility requirements of the applicable section of the INA. The
application is approved or denied based on information supplied on the form and
submitted evidentiary attachments.
The qualifying conditions for citizenship are outlined in the relevant INA sections below:
Via the INA Section 320 (most often):
(a) A child born outside of the United States automatically becomes a citizen of the
United States when all of the following conditions have been fulfilled:
(1) At least one parent of the child is a citizen of the United States, whether by
birth or naturalization.
(2) The child is under the age of eighteen years.
(3) The child is residing in the United States in the legal and physical custody of
the citizen parent pursuant to a lawful admission for permanent residence.
(b) Subsection (a) shall apply to a child adopted by a United States citizen parent if the
child satisfies the requirements applicable to adopted children under section 101(b)(1).
Via INA Section 301: The following shall be nationals and citizens of the United States at
birth:
(a) a person born in the United States, and subject to the jurisdiction thereof;
(b) a person born in the United States to a member of an Indian, Eskimo, Aleutian, or
other aboriginal tribe: Provided, That the granting of citizenship under this subsection
shall not in any manner impair or otherwise affect the right of such person to tribal or
other property;
(c) a person born outside of the United States and its outlying possessions of parents
both of whom are citizens of the United States and one of whom has had a residence in
the United States or one of its outlying possessions, prior to the birth of such person;
(d) a person born outside of the United States and its outlying possessions of parents one
of whom is a citizen of the United States who has been physically present in the United
States or one of its outlying possessions for a continuous period of one year prior to the
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 4 of 20

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

birth of such person, and the other of whom is a national, but not a citizen of the United
States;
(e) a person born in an outlying possession of the United States of parents one of whom
is a citizen of the United States who has been physically present in the United States or
one of its outlying possessions for a continuous period of one year at any time prior to
the birth of such person;
(f) a person of unknown parentage found in the United States while under the age of five
years, until shown, prior to his attaining the age of twenty-one years, not to have been
born in the United States;
(g) a person born outside the geographical limits of the United States and its outlying
possessions of parents one of whom is an alien, and the other a citizen of the United
States who, prior to the birth of such person, was physically present in the United States
or its outlying possessions for a period or periods totaling not less than five years, at
least two of which were after attaining the age of fourteen years: Provided, That any
periods of honorable service in the Armed Forces of the United States, or periods of
employment with the United States Government or with an international organization as
that term is defined in section 1 of the International Organizations Immunities Act (59
Stat. 669; 22 U.S.C. 288) by such citizen parent, or any periods during which such citizen
parent is physically present abroad as the dependent unmarried son or daughter and a
member of the household of a person (A) honorably serving with the Armed Forces of
the United States, or (B) employed by the United States Government or an international
organization as defined in section 1 of the International Organizations Immunities Act,
may be included in order to satisfy the physical-presence requirement of this paragraph.
This proviso shall be applicable to persons born on or after December 24, 1952, to the
same extent as if it had become effective in its present form on that date; and
(h) a person born before noon (Eastern Standard Time) May 24, 1934, outside the limits
and jurisdiction of the United States of an alien father and a mother who is a citizen of
the United States who, prior to the birth of such person, had resided in the United States.
Via INA Section 309: Children Born Out of Wedlock
(a) The provisions of paragraphs (c), (d), (e), and (g) of section 301, and of paragraph (2)
of section 308, shall apply as of the date of birth to a person born out of wedlock if(1) a blood relationship between the person and the father is established by clear
and convincing evidence,
(2) the father had the nationality of the United States at the time of the person's
birth,

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 5 of 20

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

(3) the father (unless deceased) has agreed in writing to provide financial support
for the person until the person reaches the age of 18 years, and
(4) while the person is under the age of 18 years(A) the person is legitimated under the law of the person's residence or
domicile,
(B) the father acknowledges paternity of the person in writing under oath, or
(C) the paternity of the person is established by adjudication of a competent
court.
(b) Except as otherwise provided in section 405, the provisions of section 301(g) shall
apply to a child born out of wedlock on or after January 13, 1941, and before December
24, 1952, as of the date of birth, if the paternity of such child is established at any time
while such child is under the age of twenty-one years by legitimation.
(c) Notwithstanding the provision of subsection (a) of this section, a person born, after
December 23, 1952, outside the United States and out of wedlock shall be held to have
acquired at birth the nationality status of his mother, if the mother had the nationality of
the United States at the time of such person's birth, and if the mother had previously
been physically present in the United States or one of its outlying possessions for a
continuous period of one year.
Or via repealed INA Section 321:
Section 321 of the former Act, states, in pertinent part, that:
(a) A child born outside of the United States of alien parents, or of an alien parent and a
citizen parent who has subsequently lost citizenship of the United States, becomes a
citizen of the United States upon fulfillment of the following conditions
(1) The naturalization of both parents; or
(2) The naturalization of the surviving parent if one of the parents is deceased; or
(3) The naturalization of the parent having legal custody of the child when there
has
been a legal separation of the parents or the naturalization of the mother if the
child was born out of wedlock and the paternity of the child has not been
established by legitimation, and if
(4) Such naturalization takes place while said child is under the age of 18 years;
and
(5) Such child is residing in the United States pursuant to a lawful admission for
permanent residence at the time of the naturalization of the parent last
naturalized under clause (2) or (3) of this subsection, or thereafter begins to
reside permanently in the United States while under the age of 18 years.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 6 of 20

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

Relevant IT systems
Individuals may use their myUSCIS online account to electronically file Form N-600.
Once submitted, the Form N-600 is transferred to USCIS Electronic Immigration System
(USCIS ELIS) for case processing.
Previously, the N-600 was processed and stored in CLAIMS 4. At the end of this calendar
year, USCIS will begin processing the Form N-600 in USCIS ELIS. Form N-600s previously
ingested into CLAIMS 4 will continue being processed in CLAIMS 4 until the form is
approved/denied. All newly filed Form N-600s will solely be processed in USCIS ELIS.
USCIS anticipates that USCIS ELIS will become the primary system for storing data from
newly filed N-600s starting at the end of the calendar year. Form N-600 and its
supplemental evidence 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.
The authority to collect, store, and use the information requested on this form, and the
associated evidence, is set forth in Sections 332, 341, 301, 309, 320 and repealed 321 of
the Immigration and Nationality Act (INA) and Title 8 of Code of Federal Regulations (8
CFR) Parts 341, 301, 309, 320 and repealed 321.

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

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 7 of 20

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

☐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 complete the form on behalf of
the applicant.
☐Business entity.
If a business entity, is the only
information collected business contact
information?
☐Yes
☐No
☐Law enforcement.
☐DHS employee or contractor.

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

☒ Other individual/entity/organization that is
NOT the record subject. Please describe.
This could include a legal custodian/guardian
who is not quite a legal representative, but who
has no objection to the child naturalizing. An
interpreter may also complete the form on behalf
of the applicant.
☒ Paper.
☒ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via
the internet)
Provide link: https://www.uscis.gov/n-600

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-600. However, there were data elements that were not accounted for on the previous

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 8 of 20

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

PTA adjudication. The list below contains a full inventory of PII collected by type of
individual.
Information about the Applicant:

























Eligibility basis for filing N-600 (biological child of U.S. citizen parent or adopted
child of U.S. citizen parent)
Alien Number
Full name
Name exactly as it appears on Permanent Resident Card
Other names used
Social Security number
USCIS Online Account Number
Date of birth
Country of birth
Country of prior citizenship or nationality
Gender
Mailing address
Physical address
Current marital status
Service in U.S. Armed Forces as a member or veteran
Information about admission into the United States and current immigration
status (port-of-entry city/town, state, date of entry, name used at time of entry,
passport number, travel document number, country of issuance for passport or
travel document, date of issuance for passport or travel document, current
immigration status in the U.S., date and USCIS Office of lawful permanent resident
status through adjustment)
Previous application for certificate of citizenship or U.S. passport
Permanent resident status abandonment
Information on adoption (city/town, state, and country of adoption, date of
adoption, date legal custody began, date physical custody began)
Information on re-adoption in the U.S. (city/town, state, and country of adoption,
date of adoption, date legal custody began, date physical custody began)
Marital status of parents at the time of applicant’s birth
Marital status of parents after applicant’s birth
Residence in the U.S. in the legal and physical custody of U.S. citizen parents

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 9 of 20

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













History of absences from the U.S. (date left the U.S., date of return to the U.S.,
city/town and state of entry upon return to the U.S.)
Ethnicity
Race
Height
Weight
Eye color
Hair color
Daytime phone number
Mobile phone number
Email address
Signature

Information about Applicant’s U.S. citizen biological parents (or adoptive parents):
 Full name
 Date of birth
 Country of birth
 Country of citizenship or nationality
 Physical address
 Information about U.S. citizenship or naturalization status (certificate of
citizenship number, A-Number, place of naturalization, city/town, state of
naturalization, certificate of naturalization number, date of naturalization)
 Loss of U.S. citizenship
 Marital history (Number of times parent has been married and current marital
status)
 Information about Parent’s current spouse (full name, date of birth, country of
birth, country of citizenship or nationality, physical address, date of marriage,
city/town, state, and country of marriage, immigration status, if spouse is also
biological or adopted parent)
 Dates of physical presence in the U.S.
 Information about service in U.S. Armed Forces (dates of service and type of
discharge)
Information about the Interpreter:
 Full name
 Organization name
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 10 of 20

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








Mailing address
Daytime phone number
Mobile phone number
Email address
Certification of fluency
Signature

Information about the Preparer:
 Full name
 Business name
 Mailing address
 Daytime phone number
 Mobile phone number
 Email address
 Signature
 G-28 ID number
Information about the Immigration Services Officer:
 Full name
 Title
 Signature
 Recommendation
Information about the District Director or Field Office Director:
 Concurrence determination
 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
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.)
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 11 of 20

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

☐ Bank Account, Credit Card, or other
financial account number
☒ Other. Please list: USCIS Online
Account Number

☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
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 applicant’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.
USCIS collects this SPII to identify the applicant and the person(s) transmitting
citizenship. The required information assists the Immigration Services Officer in
verifying identities, validating immigration history, and determining the applicant’s
eligibility for the benefit sought. It would be virtually impossible otherwise to
demonstrate that the parent or grandparent could transmit U.S. citizenship.
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
600.
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,
It will be stored in the applicant’s A-File.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
Form N-600 data will be stored in both CLAIMS 4 and
USCIS ELIS. No new forms will be processed using
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 12 of 20

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?

CLAIMS 4 and forms filed prior to the end of this
calendar year will continue being processed in
CLAIMS 4. All new forms will solely be processed in
USCIS ELIS.
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
The form is filed through the Lockbox and is scanned
as part of the intake process. The form is then stored
in USCIS ELIS (starting at the end of the calendar
year).
☒ Manually (data elements manually entered). Please
describe.
When adjudicating a form in CLAIMS 4, the
Immigration Services Officer may make changes,
corrections, and updates to the case. He or she can
also add information the applicant inadvertently
omitted. Immigration Services Assistants have
authority to update address information when
needed.
☒ Automatically. Please describe.
As USCIS moves toward storing new N-600 data in
ELIS, these forms will be ingested at the Lockbox,
and the data will be sent automatically from
Lockbox into USCIS ELIS.
☒ 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.

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 13 of 20

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

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

Form N-600:
DAA-0566-2016-0016 covers the adjudicative decision of
Form N-600. Data is transferred to the National Archives
100 years after the individual’s date of birth.
CLAIMS 4:
DAA-0566-2017-0017 covers CLAIMS 4 records. Data is
destroyed 50 years after the last completed action.
USCIS ELIS: Pending NARA approval.
A-File: N1-566-08-11 covers A-File records as
permanent value.
The system owner is responsible for ensuring the records
are deleted or transferred in accordance with the
approved records 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.
Data from Form N-600 is entered in USCIS systems. When the information is
loaded into CLAIMS 4, it can be accessed by other USCIS offices, as well as other
DHS components. Such access allows USCIS, ICE, and CBP to verify non-immigrant
status in the performance of their duties.
While the information can be accessed by other DHS components via CLAIMS 4,
the form itself is not routinely shared with other DHS components. It is shared
when a valid “need to know” exists.
☐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.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 14 of 20

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

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 15 of 20

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:

Amanda Hoffmaster

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

April 10, 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.)

June 18, 2018
☐Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
The Privacy Notice is in draft and will be
reviewed 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.
USCIS Office of Privacy recommends designating Form N-600 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 and adjudication of
Form N-600.
• DHS/USCIS/PIA-056 USCIS ELIS which covers the processing and adjudication of most
electronically filed Form N-600s
• DHS/USCIS/PIA-071 myUSCIS Account Experience, which covers the completion and
online submission of certain USCIS forms.
USCIS Office of Privacy will update the ELIS and myUSCIS Account Experience Appendices
and send them to PRIV for publication prior to the deployment date.
SORN

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 16 of 20

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

• 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 17 of 20

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

1164871
July 13, 2018
July 13, 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:

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:
Privacy Notice required
PTA:
Choose an item.
Click here to enter text.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 18 of 20

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

PIA:

SORN:

PIA Appendix update required
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:
DHS/USCIS/PIA-056 USCIS ELIS;
DHS/USCIS/PIA-071 myUSCIS Account Experience
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 submitting this PTA to discuss Form N-600, Application for Certificate of Citizenship,
because USCIS plans to support the electronic filing of Form N-600 in myUSCIS. Form N600 is used by respondents who are requesting a Certificate of Citizenship because they
were born outside the United States to a U.S. citizen parent. This form is also used by
applicants requesting a Certificate of Citizenship because they automatically became a
citizen of the United States after birth, but before they turn 18 years of age. Form N-600
can also be filed by a parent or legal guardian on behalf of a minor child.
USCIS uses the information collected on Form N-600 to determine if a Certificate of
Citizenship can be issued to the applicant. The collected PII and SPII assists the
Immigration Services Officer in verifying identities, validating immigration history, and
determining the applicant’s eligibility for the benefit sought. The information on Form N600 is supported with evidence submitted by the applicant.
Individuals may use their myUSCIS online account to electronically file Form N-600. Once
submitted, the Form N-600 is transferred to USCIS Electronic Immigration System (USCIS
ELIS) for case processing. Form N-600s previously ingested into CLAIMS 4 will continue
being processed in CLAIMS 4 until the form is approved/denied. All newly filed Form N600s will solely be processed in USCIS ELIS.
The DHS Privacy Office agrees that this is a privacy sensitive form, requiring PIA coverage.
Coverage is provided by DHS/USCIS/PIA-015 Computer Linked Application Information
Management System (CLAIMS 4), which covers information collected for the processing
and adjudication of in-process Form N-600s. Coverage is also provided by DHS/USCIS/PIA056 USCIS ELIS, which covers the processing and adjudication of the Form N-600s that will
be filed (mostly electronically), and by DHS/USCIS/PIA-071 myUSCIS Account Experience,
which covers the online submission of N-600. However, an appendix update is required for
both of the latter PIAs to account for this form.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 19 of 20

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

SORN coverage is also required, and is provided by DHS/USCIS-001 A-File, which covers
immigration files, and DHS/USCIS-007 Benefits Information System, which covers non-Afile content.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
Page 20 of 20