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

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

Privacy Threshold Analysis (PTA)

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

Form I-485

Form Title:

Application to Register Permanent Residence or Adjust Status

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Field Operations
Directorate(FOD)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form I-485, Application to Register Permanent Residence or Adjust
Status
June 30, 2019
OMB Control
OMB No. 1615-0023
OMB Expiration
Number:
Date:
Collection status: Revision
Date of last PTA (if May 19, 2016
applicable):
PROJECT OR PROGRAM MANAGER
Name:
Office:
Phone:

Name:

David P. Johnson

Title:
Email:

Field Operations
202-699-1514

Adjudications Officer
[email protected]

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Evadne Hagigal

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

Office:
Phone:

Office of Policy & Strategy
202-272-0993

Title:
Email:

Project Manager
[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 is updating Form I-485 to clarify reasons for the application and provide more
detailed instructions. USCIS is standardizing the Biometric Services appointment
language on forms that already request the collection of biometrics. The Form I-485
already included the Biometric service appointment language, but is now being revised.
The Immigration Biometric and Background Check SORN is added as coverage.
Form I-485, Application to Register Permanent Residence or Adjust Status
The Immigration and Nationality Act (INA) permits a foreign national to obtain a green
card (permanent residence) while in the United States if the individual was inspected
and admitted or paroled into the United States, is able to meet all eligibility requirements
for a green card in a particular category, and is not otherwise barred from adjustment.
The common term for this process is “adjustment of status.”
The INA provides a foreign national two primary paths to permanent resident status.
1. Adjustment of status – the process by which an eligible individual already in the
United States can get a green card without having to return to their home country to
complete visa processing, or
2. Consular processing —the process for an individual outside the United States (or who
is in the United States but is ineligible to adjust status) to obtain a visa abroad and enter
the United States as a permanent resident. (This pathway is referred to as “consular
processing.")

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

Form I-485 is used by a person who is in the United States to apply to USCIS to adjust to
permanent resident status or to register for permanent residence.
Relevant Information Technology
The Interim Case Management Solution (ICMS) and Computer Linked Application
Information Management System (CLAIMS 3) are the IT systems associated with Form. I485. The Form I-485 and all supplemental documents related to the form are stored in
the 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 103, 245, and 264(f) of the Immigration and Nationality Act

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).

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

☒ 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.
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-485 collects information about the applicant, interpreter, and preparer.
Information collected about the Applicant includes:
 Full name
 Alias(es)
 Mailing Address
 Date of Birth
 Country of Birth
 Country of Citizenship/Nationality
 U.S. Social Security Number
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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A-Number
USCIS Online Account Number
Passport or Travel Document Number
Passport or Travel Document Expiration Date
Country that Issued Passport or Travel Document
Place and Date of Late Arrival
I-94 Number
Immigration Status of Last Arrival
Current USCIS Status
Status Expiration Date
Address History for Last Five Years
Parents’ Full Names
Parents’ Date of Birth
Parents’ Sex
Parents’ Place of Birth
Parents’ Current Town and Country of Residence
Marital Status
Spouse’s Full Name
Spouse’s Date of Birth
Date and Place of Marriage to Current Spouse
Spouse’s Place of Birth
Marital History
Children’s Full Names
Children’s A-Numbers
Children’s Dates of Birth
Children’s Country(ies) of Birth
Height
Weight
Ethnicity
Race
Eye Color
Hair Color
Employment History for Last Five Years
Entry/Exit History
Nonimmigrant Visa Number
Present and Past Memberships or Affiliations

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

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Criminal History
Disability(ies) and/or Impairment(s) Accommodations
Phone Number
Email Address
Signature

Information collected about the Preparer includes:
• Full Name
• Business or Organization Name
• Address
• Email Address
• Phone Number
• Signature
Information collected about the Interpreter includes:
• Full Name
• Language Used
• Business or Organization Name
• Address
• Email Address
• Phone Number
• Signature
Information collected about Attorney or Accredited Representative include:
• Whether a G-28 was completed (yes/no)
• Volag Number
• Attorney State Bar Number(s)
• USCIS Online Account Number

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

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

☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
Sections 103, 245, and 264(f) of the Immigration and Nationality Act
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 social security number may be used to verify the applicant. The SSN is used when
investigating potential fraud or criminal issues in various records and systems, as it is a
unique identifier, just as are fingerprints. For young men between the ages of 17 and 9
months up to their 26th birthday, USCIS sends that information (name, DOB, SSN) along
to the Selective Service (SS) for their registration. Without the SSN, the SS cannot provide
on-line evidence of registration. If a young man only lists a name, DOB, and address but
no SSN on his I-485, then the only way to later get proof of Selective Service registration
is by manual inquiry, and the individual must remember the address that was listed on
his I-485 or the SS will be unable to pull that information from their records.
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.
A Privacy Notice is included in the corresponding
form instruction.
☐No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
Alien File
completed IC/forms?
☒ Electronic. Please describe the IT system that will
store the data from the form.
CLAIMS 3 and ICMS
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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.
EDMS
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
Some information is submitted manually by
employees with Lockbox. The Lockbox uses both,
with the first step being an automatic scan to
capture recognizable information. Then, for fields
that we have designated for additional
verification, Lockbox contract staff are manually
reviewing, verifying, and correcting, if needed.
☒ Automatically. Please describe.
Initial Automatic scan to capture recognizable
information.

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.
Records may be retrieved a personal identifier or a
combination of personal identifiers such as name and
date of birth and A number

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

.☐By a non-personal identifier. Please describe.
Click here to enter text.
DAA-0566-2016-0018 covers Form I-485.
DAA-0566-2016-0009 covers CLAIMS 3 records. Data
is destroyed 50 years after the last completed action.
ICMS is a non-record system.
ICMS is a non-record system.

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

N1-566-08-11 covers A-Files records which were
deemed permanent. USCIS transfers A-Files 100 years
after the individual’s date of birth.
The system owner is responsible for ensuring the
records are deleted 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.
Click here to enter text.
☐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:

Nina Robinson

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

November 2, 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 2, 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.
The Office of Privacy recommendation is to designate Form I-485 as privacy sensitive with
coverage under DHS/PIA/USCIS-016(a) CLAIMS 3 and Associated Systems,
DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records,
DHS/USCIS-007 Benefits Information System, and DHS/USCIS-018 Immigration Biometric
and Background Check (IBBC) System of Records.

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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

1171122
November 14, 2018
November 14, 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:

SORN:

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.
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 updates to the instructions and standardize
language on Form I-485. Form I-485 is used by a person who is in the United States to
apply to USCIS to adjust to permanent resident status or to register for permanent
residence. The form already included biometric service appointment language, but it is
being revised and standardized.
The DHS Privacy Office agrees with USCIS Privacy that Form I-485 is a privacy sensitive
information collection that requires PIA coverage because it collects PII from members of
the public. PRIV finds that DHS/USCIS/016(a) CLAIMS 3 provides adequate coverage as it
assesses the risks surrounding CLAIMS 3, which is the central database where the I-485 is
collected, stored, used, and maintained.
SORN coverage is necessary for Form I-485 because it collects information that is retrieved
by a unique identifier. DHS/USCIS/ICE/CBP-001 A-File SORN covers the information
collected on the Form I-485 because information collected by the form is maintained in the
individual’s A-File as they pass through the immigration process. DHS/USCIS-007 Benefits
Information System (BIS) SORN supports the electronic processing of immigration benefits
in CLAIMS 3 that may not be stored in the A-File. DHS/USCIS-018 Immigration Biometric
and Background Check has also been added as additional coverage.

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