I-765 Privacy Threshold Analysis (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:

I-765 and I-765WS
Application for Employment Authorization and Worksheet

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Service Center
Operations

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form I-765, Application for Employment Authorization and
Form I-765WS, Worksheet
OMB Control
1615-0040
OMB Expiration
May 31, 2020
Number:
Date:
Collection status:
Revision
Date of last PTA (if
June 1, 2020
applicable):

Name:
Office:
Phone:

Name:

PROJECT OR PROGRAM MANAGER
Michelle L. Young
Service Center Operations
Title:
Adjudication Officer (Policy)
(802) 527-3012
Email:
[email protected].
gov
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Melanie Frank

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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 and
Strategy
(202) 527-4488

Title:

PRA Clearance Officer

Email:

[email protected]
.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.
2021 Revision
USCIS is submitting this updated PTA to document the electronic ingestion of the Form I765 via myUSCIS Account Experience, a customer service tool that provides an online
public-facing portal for USCIS customers to access information related to their
applications, petitions, and service requests will now be available. The electronic
ingestion of the Form I-765 will support the following eligibility categories which will be
processed in USCIS Electronic Immigration System (USCIS ELIS):
• c(3)(A): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - Pre-Completion OPT
• c(3)(B): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - Post-Completion OPT
• c(3)(C): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - 24-Month Extension for STEM Students
(Students With a Degree in Science, Technology, Engineering, or Mathematics)
Form I-765, Application for Employment Authorization
Aliens who are temporarily in the United States and eligible for employment
authorization or authorized to be employed incident to their status may file a Form I765, Application for Employment Authorization, to request an Employment
Authorization Document (EAD).
I-765 Worksheet (WS)

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

An EAD based on a grant of deferred action requires a showing of economic necessity. To
facilitate this economic necessity review, a separate worksheet (Form I-765WS) was
created. There is a general presumption that Deferred Action for Childhood Arrivals
(DACA) requestors will need to work given their undocumented circumstances and the
fact that they are not generally anticipated to have independent means. Absent evidence
of sufficient independent financial resources, the Form I-765WS is sufficient to establish
economic need without any further economic analysis. Additionally, the agency decided
that all deferred action I-765 applicants must complete the I-765WS after it was
determined to create the I-765WS for DACA. The Form I-765WS includes a certification
section so that individuals can sign the form.
Fee Rule
The Fee final rule adjusts certain immigration and naturalization benefit request fees
charged by USCIS. It also makes changes related to setting, collecting, and administering
fees. Fee schedule adjustments are necessary to recover the full operating costs
associated with administering the nation’s immigration benefits system, safeguarding its
integrity, and efficiently and fairly adjudicating immigration benefit requests, while
protecting Americans, securing the homeland, and honoring our country’s values. This
final rule also makes certain adjustments to fee waiver eligibility, filing requirements for
nonimmigrant workers, premium processing service, and other administrative
requirements. Form I-765/I-765WS and the instructions were previously revised as a
result of the Fee Rule1. The Fee Rule PTA was adjudicated on March 27, 2020.
Relevant IT systems
Individuals may submit the Form I-765 package by paper or electronically. Online filing
for the Form I-765 is available via myUSCIS, a customer service tool that provides an
online public-facing portal for USCIS customers to access information related to their
applications, petitions, and service requests. Individuals may use their myUSCIS online
account to electronically file Form I-765. Currently online filing will support the
following eligibility categories that will be processed in USCIS ELIS:
• c(3)(A): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - Pre-Completion OPT
• c(3)(B): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - Post-Completion OPT
• c(3)(C): F-1 Student Seeking Optional Practical Training (OPT) in a Position
Directly Related to Major Area of Study - 24-Month Extension for STEM Students
(Students With a Degree in Science, Technology, Engineering, or Mathematics)
1

USCIS conducted a comprehensive biennial fee review and determined that current fees do not recover full cost.
This final rule adjusts certain immigration and naturalization benefit request fees charged by USCIS.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Once submitted, the Form I-765 is transferred to the respective IT system for case
processing. USCIS uses the following systems to process Form I-765.
• Computer Linked Adjudication Information Management System (CLAIMS 3): For
the majority of the populations of individuals who can file Form I-765, USCIS uses
the CLAIMS 3 system to process requests for employment authorization.
•

USCIS ELIS: For some populations of aliens who file Form I-765, USCIS uses the
USCIS ELIS system to process requests for employment authorization.

•

GLOBAL: Approved asylum applicants have an I-765 for employment
authorization completed via a data exchange between GLOBAL and CLAIMS3.
When an affirmative asylum application is approved by an asylum office, GLOBAL
initiates the EAD production so that information is stored in GLOBAL and
CLAIMS3. After a person has asylum status and needs an extension or
replacement EAD, they file an I-765, which is entered into CLAIMS 3.
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.
8 U.S.C. 1324a; 8 CFR 274a.12 and 274a.13

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII2)?
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.

2

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

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.
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: myUSCIS Online Account

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-765, Application for Employment Authorization collects information from the
applicant and preparer.
Information about the applicant includes:
• First Name
• Middle Name
• Last Name
• U.S Addresses (Physical and Mailing/Safe Mailing Address)
• Telephone Number(s)
• E-mail address
• Alias(es)
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

• Country of Citizenship/Nationality
• Place and date of Birth
• Gender
• Marital Status
• Social Security number (SSN), if any
• SSA Enumeration Beyond Entry questions:
• Do you want SSA to issue you a Social Security card? (Yes/No)
• SSA Consent for Disclosure (Yes/No)
• Father’s Name (Family Name, Given Name)
• Mother’s Name (Family Name, Given Name)
• USCIS Online Account Number (if any)
• Alien Number (if any)
• I-94 Number
• Passport Number
• Travel Document Number
• Country of Issuance for Passport or Travel Document
• Expiration Date for Passport or Travel Document
• Date of Last Arrival into the United States
• Place of Last Arrival into the United States
• Immigration Status of Last Arrival
• Current Immigration Status
• Student Exchange Visitor Information System (SEVIS) Number (if any)
• Eligibility Category
• If (c)(3)(C), Degree
• If (c)(3)(C), Employer’s Name as listed in E-Verify
• If (c)(3)(C), Employee’s E-Verify Company ID or Client ID
• If (c)(26), receipt number of H-1B spouse’s most recent Form I-129
• If (c)(8), yes/no arrest and/or conviction question
• If (c)(35) or (c)(36), receipt number of your Form I-140 or your
spouse’s/parent’s Form I-140
• If (c)(35) or (c)(36), yes/no arrest and/or conviction question
• If (c)(9), Immigrant Category
• Statement and Certification
• Signature
• Date of Signature
Interpreter information includes:
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

• Full Name
• Business or Organization Name (if any)
• Mailing Address
• Daytime Telephone Number
• Mobile Telephone Number
• Email Address (if any)
• Certification
• Signature
• Date of Signature
Preparer (including Accredited Representative and Attorney) information includes:
• Full Name
• Business or Organization Name (if any)
• Mailing Address
• Daytime Telephone Number
• Mobile Telephone Number (if any)
• Email Address (if any)
• Statement and Certification
• Signature
• Date of Signature

Form I-765 Worksheet collects the following information:
• Current Annual Income
• Current Annual Expenses
• Current Value of Assess
• Additional Information
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.)
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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
financial account number
☒ Other. Please list: USCIS Online
Account Number and SEVIS 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)), states, “Alien’s social security account number. –
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.
USCIS collects the applicant’s SSN on Form I-765, Application for an Employment
Authorization Document, in accordance with the Paperwork Reduction Act and the
Immigration and Nationality Act. The collection of the applicant’s SSN is very important
in the context of an Application for Employment Authorization Document (EAD) for a
number of reasons. First, the EAD evidences that an individual is authorized for
employment, and in the United States the SSN is the primary number associated with
employment records, tax collection, and lawful employment.
The USCIS E-Verify program uses the SSN to interface immigration records and Social
Security Administration databases. Without SSNs, we lose the integrity of this interface.
The SSN provided on the application for an EAD can be used to determine whether an
applicant has worked previously in the U.S. and if that employment was lawful.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
USCIS provides a Privacy Notice to the individual
time of collection by
on the form instructions prior to collecting any
DHS (Does the records
information.
subject have notice of
☐ No.
the collection or is
form filled out by
third party)?

3. How will DHS store the IC/form responses?

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

a. How will DHS store
the original,
completed IC/forms?

☒ Paper. Please describe.
The form will be stored in the receipt file.
☒ Electronic. Please describe the IT system that will
store the data from the form.
Computer Linked Adjudication Information
Management System (CLAIMS 3): For the majority
of the populations of individuals who complete
Form I-765, it will be entered into CLAIMS 3.
USCIS Electronic Immigration System (USCIS
ELIS): For some populations of individuals who
complete Form I-765, it will be entered into USCIS
ELIS.
GLOBAL: Approved asylum applicants have an I765 for employment authorization completed via
a data exchange between GLOBAL and CLAIMS3.
When an affirmative asylum application is
approved by an asylum office, GLOBAL initiates
the EAD production so that information is stored
in GLOBAL and CLAIMS3. After a person has
asylum status and needs an extension or
replacement EAD, they file an I-765, which is
entered into CLAIMS 3.
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Form I-765 may also be scanned using the
Enterprise Document Management System (EDMS).

b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
For those I-765s direct filed at a Service Center,
data entry clerks manually enter data from the
form into CLAIMS 3.
☒ Automatically. Please describe.

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

For those I-765s filed through a Lockbox, the form,
fee and support documents are scanned and the
data is populated using Optical Character Reader
technology. The data is then verified and
corrected, if needed, by keying clerks via OnBase
(JPMorgan data collection system). The data
(scanned and keyed) is sent USCIS (scanned is
stored in EDMS, keyed is stored in CLAIMS 3 or
ELIS depending on form type).
Individuals may use their myUSCIS online account
to electronically file Form I-765. The information
is transferred to ELIS for processing.
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.3 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Receipt number, USCIS Online Account Number,
SSN, A-Number, Name, Date of Birth, or a
combination of the data elements.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
Form I-765: Destroy 7 years from the expiration of
the authorized employment period.
[DAA-0566-2016-0005-0001]
CLAIMS 3: CLAIMS 3 deletes and destroys records 50
years from the date of the last completed action [DAA0566-2016-0009 and DAA-0566-2016-0013]
USCIS/EDMS: Records are retained permanently.
[EDMS: N1-566-08-17]

3

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

e. How do you ensure
The system owner is responsible for ensuring the
that records are
records are deleted in accordance with the records
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?
☒ Yes, information is shared with other DHS components or offices. Please describe.
The information from the form may be shared to other ICE and CBP via
system access.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
USCIS will share Form I-765 information with SSA to produce a Social
Security number for the applicant, if consent is provided.
☐ 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:

Shannon DiMartino

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

December 9, 2020

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.)

February 11, 2021
☒ 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.
USCIS is submitting this updated PTA to document the electronic ingestion of the Form I765/I-765WS via myUSCIS Account Experience. Currently online filing will support the
following eligibility categories that will be processed in USCIS ELIS:
• c(3)(A): F-1 Student Seeking Optional Practical Training (OPT) in a Position Directly
Related to Major Area of Study - Pre-Completion OPT
• c(3)(B): F-1 Student Seeking Optional Practical Training (OPT) in a Position Directly
Related to Major Area of Study - Post-Completion OPT
• c(3)(C): F-1 Student Seeking Optional Practical Training (OPT) in a Position Directly
Related to Major Area of Study - 24-Month Extension for STEM Students (Students
With a Degree in Science, Technology, Engineering, or Mathematics)
The USCIS Office of Privacy recommendation is to designate as privacy sensitive, requiring
PIA and SORN coverage. Coverage can be found under the following:
PIAs
• DHS/USCIS/PIA-016(a) Computer Linked Application Information Management
System (CLAIMS 3) and Associated Systems, which covers the collection of
information collected on the I-765 and stored in CLAIMS 3
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

•

DHS/USCIS/PIA-056 USCIS ELIS, which covers the filing of the Form I-765 using
USCIS ELIS
• DHS/USCIS/PIA-061 Benefit Request Intake Process, which covers the benefit
intake and processing of the Form I-765
• DHS/USCIS/PIA-071 myUSCIS Account Experience, which covers the completion
and online submission of certain USCIS forms.
SORNs
• DHS/USCIS/ICE/CBP-001-Alien File, Index, and National File Tracking System of
Records, which covers the use, collection, and storage of applicant information in
the A-File.
• DHS/USCIS-007 Benefits Information System, which covers the use, collection, and
storage of benefit requester and representative information

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

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Jennifer Kimmons

Date approved by DHS Privacy Office:
Date approved by DHS Privacy Office:
PTA Expiration Date

Max Binstock
February 12, 2021
February 12, 2024

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:

DHS PRIV has not received this ICR/Form.

Date IC/Form Approved Click here to enter a date.
by PRIV:
Privacy Act
e(3) statement update is required.
Statement:
SORNs listed in the Privacy Notice need citations
PTA:
Choose an item.
Click here to enter text.
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
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Associated Systems; DHS/USCIS/PIA-056 USCIS ELIS; DHS/USCIS/PIA061 Benefit Request Intake Process; and DHS/USCIS/PIA-071 myUSCIS
Account Experience
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 10, 2019, 84 FR 54622

DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS is submitting this updated PTA to discuss an update to the Form I-765 and I-765WS
which will now be electronically ingested via myUSCIS Account Experience, a customer
service tool that provides an online public-facing portal for USCIS customers to access
information related to their applications, petitions, and service requests will now be
available. The electronic ingestion of the Form I-765 will support additional F-1 eligibility
categories which will be processed in USCIS Electronic Immigration System (USCIS ELIS).
The DHS Privacy Office (PRIV) finds that this form is a privacy sensitive information
collection requiring PIA coverage because PII is collected from members of the public. PRIV
agrees with USCIS Privacy that PIA coverage is provided by DHS/USCIS-016(a) CLAIMS 3 &
DHS/USCIS/PIA-056 ELIS, which cover the storage and processing of forms I-765 and I765WS data elements in their systems. PIA coverage is also provided by DHS/USCIS/PIA061 Benefit Request Intake Process, which covers the benefit intake and processing of the
Form I-765 and DHS/USCIS/PIA-071 myUSCIS Account Experience, which covers the
completion and online submission of this USCIS form.
PRIV finds that SORN coverage is required because information is retrieved by unique
identifier. Coverage is provided by DHS/USCIS/ICE/CBP-001 Alien File, which covers the
collection, use, and maintenance of PII to facilitate administration of benefits and
enforcement of provisions under the INA and related immigration statutes. Coverage is
also provided by DHS/USCIS-007 BIS SORN, which covers the use of PII in intake,
processing, and decisional data that may not interact with the A-file.
A Privacy Notice was also submitted with this PTA. The Privacy Notice should be updated
to include the proper citations for the A-FILE SORN and BIS SORN.

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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