PIA 006(a)

Privacy Impact Assessment Update
for the

Systematic Alien Verification for Entitlements
Program
DHS/USCIS/PIA-006(a)
July 27, 2012
Contact Point
Brian C. Hobbs
Privacy Branch Chief, Verification Division
USCIS/Enterprise Services Directorate
(202) 443-0114
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
202-443-1717

Privacy Impact Assessment Update
USCIS Verification Division SAVE Program
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Abstract
The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services
(USCIS), Verification Division is publishing this update to the Systematic Alien Verification for
Entitlements (SAVE) Program Privacy Impact Assessment (PIA) dated August 26, 2011. SAVE is a feebased inter-governmental initiative designed to help federal, state, tribal, and local government agencies
confirm immigration status prior to the granting of benefits and licenses, as well as for other lawful
purposes. The purpose of this update is to: (1) describe the new collection of foreign passport country of
issuance (COI) from agencies issuing benefits and from the United States Visitor and Immigrant Status
Indicator Technology (US-VISIT) Arrival and Departure Information System (ADIS); 1 (2) describe the
addition of Enterprise Citizenship and Immigration Services Centralized Operational Repository
(eCISCOR); (3) describe the decommissioning of the Image Storage and Retrieval System (ISRS) and
replacement by the Customer Profile Management System (CPMS); and (4) describe the
decommissioning of the Reengineered Naturalization Applications Casework System (RNACS) and
replacement by Claims Linked Application Information Management System 4 (CLAIMS 4). 2

Introduction
USCIS administers the SAVE Program. SAVE is a fee-based inter-governmental initiative
designed to help federal, state, tribal, and local government agencies and licensing bureaus confirm
immigration status information. USCIS confirms of immigration status to the extent that such the
confirmation is necessary to enable the federal, state, tribal, or local government agencies to make
decisions related to: (1) determining eligibility for a federal, state, or local public benefit; (2) issuing a
license or grant; (3) issuing a government credential; (4) conducting a background investigation; or (5)
any other lawful purpose.
A federal, state, tribal, or local government agency that provides a public benefit or license, or
that is otherwise authorized by law to engage in an activity related to the verification of immigration
status, may enroll in SAVE as a customer agency. By using SAVE, federal, state, tribal, and local
customer agencies can request immigration status information in order to make a determination regarding
the applicant’s eligibility for a benefit or a license. It is important to note that SAVE does not make
determinations on an applicant’s eligibility for a specific benefit or license, but it does provide the
necessary information to the agencies to allow them to make an informed decision prior to issuing
benefits or licenses. The customer agency analyzes the SAVE response against the agency’s own
eligibility criteria to make an award determination. SAVE does not know the final outcome of the benefit
adjudication. 3

1

See PIA at DHS/NPPD/USVISIT/PIA-005 Arrival and Departure Information System (ADIS) and updates and
SORN at DHS/USVISIT-001 Arrival and Departure Information System 72 Fed. Reg. 47057 (August 22, 2007).
2
See PIA at DHS/USCIS/PIA-015 Computer Linked Applcation Information Management System (CLAIMS4) and
updates and SORN at DHS/USCIS-007 Benefits Information System 73 Fed. Reg. 56596 (Spetember 29, 2008).
3
See the original SAVE Program PIA (DHS/USCIS/PIA-006) available at www.dhs.gov/privacy for additional
information on the status verification process.

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USCIS is updating the SAVE Program PIA dated August 26, 2011, to: (1) describe the new
collection and verification of COI from US-VISIT ADIS; (2) describe the SAVE Program’s new interface
with eCISCOR; and (3) discuss the decommissioning of ISRS and RNACS. The functionality previously
provided by ISRS and RNACS will be replaced with CPMS and CLAIMS 4, respectively.

Country of Issuance
SAVE currently uses the I-94 number 4 as a primary identifier 5 to determine immigration status
for non-immigrants. However, the U.S. Customs and Border Protection (CBP) is in the process of
automating the I-94 system to increase efficiency and streamline the admission process for travelers to the
United States. However, since SAVE depends on the integrity of the I-94 number and the automation
effort is still underway, USCIS has proactively developed a new primary identifier that is independent of
the I-94 process. SAVE will now have the capability to determine citizenship status using a combination
of foreign passport number and COI. Combining these two data elements makes them a primary
identifier. This enhancement requires new collection of COI from benefit applicants by the benefit
granting agency. SAVE will compare this information with data in ADIS through an existing system
interface. The collection of COI improves the efficiency of the verification process and addresses changes
in the admission process for travelers.
The specific changes required to accommodate this initiative are as follows:
•

USCIS will update the SAVE interface to enable agencies to enter foreign passport
number and COI.

•

SAVE will receive COI through the existing ADIS connection.

eCISCOR
In situations where SAVE cannot automatically determine an applicant’s immigration status,
status verifiers will use eCISCOR 6 to manually verify the immigration status of benefit applicants.
eCISCOR is a read-only database that consolidates immigration and naturalization information from
several USCIS data systems. Verifying applicant information in eCISCOR improves the efficiency of
status verifiers by allowing them to view data from multiple systems in one centralized repository. Status
verifiers will use eCISCOR to verify an applicant’s A-Number, name (last, first, middle), DOB, form
numbers and Certificate of Citizenship number. The verification process is not changed by the use of
eCISCOR.
eCISCOR is a centralized source of data from other USCIS systems. As a result, there is a risk
that data in eCISCOR may not accurately reflect the underlying data in the source system. This risk is
mitigated through the management and updating of eCISCOR by USCIS. Additionally, status verifiers

4

Form I-94 is a DHS form generally issued to aliens at the time they lawfully enter the United States. Form I-94 is
used to document status in the United States, the length of stay, and departure.
5
A primary identifier is a value that relates to a single person for the purpose of searching a database.
6
The PIA for eCISCOR, Enterprise Citizenship and Immigration Services Centralized Operational Repository, is
available at www.dhs.gov/privacy.

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have the capability to verify data in the source systems that feed eCISCOR if there is a data integrity
issue.

ISRS and CPMS
USCIS decommissioned the ISRS subsystem, which provided access to biometric and related
biographic information used to verify the identity of registered aliens and to police illegal entry into and
residence in the United States. ISRS was a centralized repository of USCIS biometrics data including the
photo, pressprint, and signature of applicants who have been issued a Permanent Resident Card or
Employment Authorization Document (EAD) (Form I-766). SAVE used ISRS as part of the initial step in
the verification process, as outlined in the SAVE PIA.
USCIS continues to view biometric information of all individuals who have been issued a
Permanent Resident Card (Form I-551) or an EAD by USCIS. However, with the decommissioning of
ISRS, SAVE status verifiers will now use the Customer Profile Management System (CPMS) to manually
verify the validity of a benefit seeker’s Permanent Resident Card or EAD if SAVE cannot automatically
determine an applicant’s immigration status. In such cases, a benefit agency submits a Form G-845,
Document Verification Request. Form G-845 requires an agency to attach a photocopy of the Permanent
Resident Card or EAD that a benefit seeker used for verification. Status verifiers will use CPMS to
validate the photograph, signature, receipt number, name (Last, First, Middle), DOB, country of birth,
form number, and expiration date of the provided document.

RNACS
USCIS decommissioned the RNACS subsystem which provided case tracking and management
capability for naturalization casework. Status verifiers used RNACS and CLAIMS 4 to manually verify
Naturalization Certificate information. Prior to the decommissioning of RNACS, USCIS migrated all
open Application for Citizenship cases to CLAIMS 4. Status verifier will now use CLAIMS 4to verify
this information.

Reason for the PIA Update
USCIS is updating the SAVE Program PIA dated August 26, 2011 to assess the privacy impacts
associated with: (1) the new collection of foreign passport COI from agencies issuing benefits and from
US-VISIT ADIS; (2) the addition of eCISCOR; (3) the decommissioning of the ISRS and replacement
by CPMS; and (4) the decommissioning of the RNACS.
As a result of this update, the SAVE Program will continue to electronically receive all data it
currently obtains from DHS/US-VISIT ADIS and other supporting databases, with the exception of
RNACS and ISRS, as those two databases were decommissioned.
The COI remains in line with the original purpose of the program and does not create any
significant new privacy risks for affected individuals. The privacy impact for the individual providing the
foreign passport COI is minimal, as he may already share the COI with the benefit-granting agency by
presenting a foreign passport as part of the application process with the agency. By entering this

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information into SAVE, it will increase the accuracy of matching an individual passport number with the
correct individual and returning an accurate benefit eligibility determination.

Privacy Impact Analysis
In each of the below sections consider how the system has changed and what impact it has on the below fair
information principles. In some cases there may be no changes and indicate as such.

The System and the Information Collected and Stored within the System
SAVE will collect and use COI from ADIS to enhance the verification process. The collection
and use of the COI by SAVE will enable the automatic verification of benefit applicants using a foreign
passport number. Foreign passport number and COI are electronically accessed in ADIS, an existing
system interface, during the verification process
The creation of a new primary identifier based on foreign passport number and COI could pose a
privacy risk if the passport is lost or compromised and used by an unauthorized individual to apply for
benefits. All identity documents pose a risk of unauthorized use if lost or compromised. However, USCIS
has a monitoring and compliance team that monitors SAVE transactions for fraud, misuse, and abuse. Part
of that monitoring includes reviewing transactions to see if certain primary identifiers are being used
beyond a typical threshold for benefit applicants.
ADIS is not the original source of COI. As a result, receiving COI from ADIS poses the risk that
the data is not accurate. This risk was previously identified in the ADIS PIA (DHS/NPPD/USVISIT/PIA005(a)). ADIS mitigates this risk by receiving some duplicative PII as an intentional mechanism to
ensure the accuracy of the information. This data integrity mechanism helps improve the reliability of the
ADIS data.
The decommissioning of RNACS and the migration to CLAIMS 4 does not result in an additional
privacy risk, as SAVE already connects to CLAIMS 4. USCIS identified CLAIMS 4 as a source in
previous PIAs and USCIS is not receiving any additional information from CLAIMS 4 as a result of this
change.
There is no additional privacy risk as a result of switch data sources from ISRS to CPMS. CPMS
fully replaced all functionality of ISRS and USCIS will not receive any additional information as a result
of this change.
There is no change in storage as a result of this update. USCIS will continue storing and
maintaining all transactional data in the Verification Information System (VIS), which is the underlying
technology for SAVE. Since there is no change to the storage, the privacy impact has not changed.

Uses of the System and the Information
The SAVE program continues to check immigration status for granting benefits, licenses, and
other lawful purposes as described in the previously published SAVE PIA (DHS/USCIS/PIA-006). This
update creates no increased privacy impact. SAVE will now use the combination of foreign passport
number and COI as a primary identifier to query the immigration status of individuals.

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Retention
The National Archives Retention Act (NARA) schedule [N1-566-08-7], approved on June 5,
2008, has not changed. SAVE retains information for 10 years from the date of completion of the
verification, unless the records are part of an ongoing law enforcement investigation, in which case
records may be retained until completion of the investigation. This period is based on the statute of
limitations for most types of misuse or fraud possible using SAVE (under 18 U.S.C. § 3291, the statute of
limitations for false statements or misuse regarding passports, citizenship, or naturalization documents).
Since retention remains the same, there is no further privacy impact as a result of this update.

Internal Sharing and Disclosure
USCIS will continue to share and disclose information with DHS components for law
enforcement purposes when SAVE detects possible fraud and/or misuse, on a case-by-case basis. The
internal sharing and disclosure of this information remains consistent with the previously published
SAVE PIA (DHS/USCIS/PIA-006).

External Sharing and Disclosure
USCIS will continue to share and disclose SAVE information externally for law enforcement
purposes and to respond to federal, state, tribal, and local government agencies immigration status
queries. The external sharing and disclosure of this information remains consistent with the previously
published SAVE PIA (DHS/USCIS/PIA-006).

Notice
This PIA and the reissuing of the DHS/USCIS-004 SAVE Program SORN provide notice to the
changes associated with the SAVE Program.

Redress
There are no changes to the access, redress, and corrections procedures identified in the
previously published SAVE PIA (DHS/USCIS/PIA-006). This update creates no increased privacy
impact.

Technical Access and Security
The technical access and security controls for SAVE have not changed. The changes described in
this PIA update are in conformance with existing technical access and security safeguards that are
described in the previously published SAVE PIA (DHS/USCIS/PIA-006).

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Technology
There are three changes in technology as a result of this update. First, SAVE will discontinue
receiving data from ISRS and RNACS. The functionality previously provided by these subsystems will be
replaced by CPMS and CLAIMS 4. Second, SAVE will now collect COI from ADIS through an existing
system interface. Finally, status verifiers will now access eCISCOR to support the immigration status
verification process. These technology changes do not create any new significant privacy impacts.

Responsible Official

Brian C. Hobbs
Privacy Branch Chief
Verification Division, U.S. Citizenship and Immigration Services
Department of Homeland Security

Approval Signature

________________________________
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security