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:
Form Title:
Component:

Form I-918, Form I-918A, Form I-918B
Petition for U Nonimmigrant Status (including Supplements A and B)
U.S. Citizenship and
Office:
Office of Policy and
Immigration Services
Strategy (OP&S)
(USCIS)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Click here to enter text.
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:

OMB No. 0615-0104
Revision

OMB Expiration
Date:01/31/2016
Date of last PTA (if
applicable):

Click here to enter a
date.
June 7, 2012

PROJECT OR PROGRAM MANAGER
Andria Strano/Scott Whelan
OP&S/SCOPS
Title:
Policy Analyst/
Adjudications Officer
(202) 272-2906/202-705- Email:
[email protected]
9684
v/[email protected]
.gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Megan Barker

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

Office:
Phone:

Regulatory Coordination
Division
202.272.9135

Title:

PRA Compliance

Email:

[email protected]
s.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.
The Form I-918 provides an opportunity for individuals to apply for temporary
immigration benefits available to victims of serious crimes such as domestic violence,
sexual assault, and trafficking, as well as qualifying family members of these victims,
subject to specific eligibility requirements. Based on the upcoming expiration date, USCIS
is requesting an extension of the current form and instructions as they presently exist,
without change. While there have been no changes to the form, USCIS is now
documenting when USCIS forms require the collection of biometrics. The Form I-918
triggers the collection of biometrics, so the Immigration Biometric and Background
Check SORN will be added as coverage.
Background
Congress created the U nonimmigrant status (U visa) with the passage of the Victims of
Trafficking and Violence Protection Act (including the Battered Immigrant Women’s
Protection Act) in October 2000. The purpose of the U visa is to allow victims to come
forward and cooperate with law enforcement without fear of deportation or removal.
The U visa allows law enforcement to establish relationships within the immigrant
community and protect this population.
U Nonimmigrant Eligibility
To qualify for U nonimmigrant status, the individual must:
- Be a victim of one of 28 qualifying crimes (including domestic violence, sexual
assault, felonious assault, and trafficking);
- Have suffered substantial physical or mental abuse as a result of the crime;
- Possess credible and reliable information about the crime;
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

-

Have been, is being, or is likely to be helpful to law enforcement in the
investigation or prosecution of the crime; and
- Crime must have occurred in U.S. or violated U.S. law with jurisdiction where
crime occurred
The individual must also be admissible to the United States or obtain a waiver of
inadmissibility.
Form I-918, Petition for U Nonimmigrant Status
Individuals seeking U nonimmigrant status are required to submit a completed Form I918, a personal statement describing the victimization, and supplemental evidence of
eligibility requirements. The petitioner must also submit a properly completed Form I918, Supplement B (description provided below).
Form I-918, Supplement A, Petition for Qualifying Family Member of U-1 Recipient
Certain family members are eligible for a derivative U visa. To apply for a family
member, the petitioner must file a Form I-918, Supplement A. The petitioner may file
Form I-918A concurrently with Form I-918 or at a later time.
Form I-918, Supplement B, U Nonimmigrant Status Certification
Form I-918, Supplement B, U Nonimmigrant Status Certification, is a required piece of
initial evidence and must be filed concurrently with the Form I-918. Form I-918B must
be completed and signed by the law enforcement agency conducting the investigation or
prosecution of the crime. Form I-918B provides an opportunity for law enforcement to
describe the victimization of the petitioner and to provide information about how the
petitioner has been, is being, or is likely to be helpful in the investigation and/or
prosecution of the qualifying crime.
A U nonimmigrant (principal or derivative) may apply for permanent residence after
three years of continuous physical presence in the United States.

The I-918 Supplement B is not a separate form. It is a required piece of evidence for the
Form I-918.
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.

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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 authority to collect information in this form is set forth in the Immigration and
Nationality Act, 8 U.S.C. §§ 1103, 1158, 1225, 1228, and Title II of Public Law 105-100
and in the implementing regulations found at 8 CFR 214.14.

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.

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

Click here to enter text.
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.
Form I-918 and/or I-918A collect the following information regarding principal
petitioners and family members:
- Full Name
- Address
- Alien Registration Number
- Date and Place of Birth
- Country of Citizenship
- Gender and Marital Status
- Email Address
- Social Security Number
- I-94 Number
- Place and Date of Last Entry
- Passport Number, Place and Date of Issue
- Current Immigration Status
- Entries to the United States
- Criminal and Immigration History
- Address of Country Where Notification to be Sent
- Telephone Number
- Email Address
- Signature
For Family Members, Form I-918A also collects:
- Name of Former Spouse, Date Marriage Ended, Where and How Marriage
Ended
Forms I-918 and I-918A collect the following preparer information:
- Name
- Business or Organization Name
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

- Address
- Phone Number
- Email Address
- Signature
Forms I-918 and I-918A collects the following interpreter information:
- Name
- Business or Organization Name
- Address
- Phone Number
- Email Address
- Language Used
- Signature
Form I-918 Supplement B also collects the following additional information:
- Name of Certifying Official
- Title and Division/Office of Certifying Official
- Name of Head of Certifying Agency
- Agency Type
- Case Status
- Certifying Agency Category
- Case Number
- FBI or SID Number
- Assessment of Criminal Acts of which Petitioner was Victim
- Assessment of Petitioner’s Helpfulness
- Full Name, Relationship and Involvement of Culpable Family Members in
Criminal Activity
- Signature of Certifying Official
- Telephone Number of Certifying Official
- Fax Number of Certifying Official
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
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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

☐Trusted Traveler Number (Global

financial account number

Entry, Pre-Check, etc.)

☐Other. Please list:

☐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)), states, “ Notwithstanding any other provision of law, the
Attorney General is authorized to require any alien to provide the alien's social security
account number for purposes of inclusion in any record of the alien maintained by the
Attorney General or the Service.”
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 SSN and other information collected is used to identify the applicant and adjudicate
the application. The SSN is recorded by USCIS CLAIMS 3 Database. USCIS collects SSNs
(applicant, fiancé and spouse) in certain forms and enters them into CLAIMS 3 and
associated systems in conjunction with other information to verify the identity of the
applicant, fiancé, spouse, to determine the applicant’s eligibility for certain benefits.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the USCIS provides applicants with notice via a Privacy
Notice which is included on the form instructions.
time of collection by
DHS (Does the records
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,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
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

☐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.
The information is retrieved using the applicant’s Alien
Registration Number.
☐Automatically. Please describe.
Click here to enter text.

c. How would a user
☒ By a unique identifier.2 Please describe. If
search the
information is retrieved by personal identifier, please
information
submit a Privacy Act Statement with this PTA.
submitted on the
Click here to enter text.
forms, i.e., how is the
☐By a non-personal identifier. Please describe.
information
Click here to enter text.
retrieved?
d. What is the records
There is currently no approved schedule for the Iretention
918. The records office is working on a draft schedule
schedule(s)? Include
that will bucket several related forms, including the Ithe records schedule
918. It is currently in review by several offices.
number.
The system owner is responsible for ensuring the records
e. How do you ensure
are deleted in accordance with the approved records
that records are
disposed of or deleted retention schedule.
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?
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

☒ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
Information may be shared with DHS and Immigration and Customs Enforcement in
compliance with confidentiality provisions in 8 USC 1367.
☐Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.
☐No. Information on this form is not shared outside of the collecting office.

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

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

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Catherine Shorten

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

November 16, 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.)

November 21, 2018
☐Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Click here to enter text.
USCIS Office of Privacy developed a Privacy Notice
and is seeking program and OCC approval.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The Form I-918 provides an opportunity for individuals to apply for temporary
immigration benefits available to victims of serious crimes such as domestic violence,
sexual assault, and trafficking, and family members, subject to specific eligibility
requirements.
The Office of Privacy recommendation is to designate the Form I-918 and its supplements
as privacy sensitive with coverage under existing PIAs and SORNs.
PIA


DHS/USCIS/PIA-016(a) Computer Linked Application Information Management
System (CLAIMS 3) and Associated Systems

SORNS
 DHS/USCIS-001Alien File, Index, and National File Tracking SORN
 DHS/USCIS-007 Benefits Information System
 The USCIS Office of Privacy also recommends adding the Immigration Biometric and
Background Check SORN as coverage. Although the form itself does not cover the
collection of biometrics, the form requires individuals to schedule a biometrics
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

collection appointment at an Application Support Center. Moving forward, USCIS
plans to add this SORN as coverage for all forms that require biometric collection.

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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

Click here to enter text.
November 23, 2018
November 23, 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/USCIS/PIA-016(a) Computer
Linked Application Information Management System (CLAIMS 3) and Associated
Systems

If a PIA update is required, please list: Click here to enter text.
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/USCIS-018 Immigration Biometric and Background Check (IBBC)
System of Records, July 31, 2018, 83 FR 36950
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 to discuss Form I-918, which is used by individuals to apply
for temporary immigration benefits available to victims of serious crimes such as domestic
violence, sexual assault, and trafficking, as well as qualifying family members of these
victims, subject to specific eligibility requirements.
Individuals seeking U nonimmigrant status are required to submit a completed Form I-918,
a personal statement describing the victimization, and supplemental evidence of eligibility
requirements. The petitioner must also submit a properly completed Form I-918,
Supplement B, must be completed and signed by the law enforcement agency conducting
the investigation or prosecution of the crime. Certain family members are eligible for a
derivative U visa. To apply for a family member, the petitioner must file a Form I-918,
Supplement A. The petitioner may file Form I-918A concurrently with Form I-918 or at a
later time.
The DHS Privacy Office finds this form is privacy sensitive, requiring PIA coverage.
Coverage is provided by DHS/USCIS/PIA-016(a) CLAIMS 3. PRIV recommends that
coverage also be provided by the planned Special Protected Classes PIA.
SORN coverage is also required, and is provided by the A-File, BIS, and Immigration
Biometric and Background Check SORNs.

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