Department of Homeland Security Privacy Impact Assessement Update

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Privacy Impact Assessment
for the

Content Management Services
DHS Reference No. DHS/USCIS/PIA-079(a)
October 15, 2024

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Abstract
The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services
(USCIS) is expanding its use of the Content Management Services (CMS) to ingest and manage
immigration-related content from other producers of Alien File content (hereafter A-File), which
includes U.S. Immigration and Customs Enforcement (ICE), U.S. Customs and Border Protection
(CBP), the Department of Justice’s Executive Office for Immigration Review (DOJ-EOIR)
Electronic Court of Appeals System (ECAS), and the Department of State (DOS). Content
Management Services will also interface with USCIS’s Person Centric Identity Services (PCIS)
via an Application Program Interface (API). 1 This model for managing content aligns with
USCIS’s vision to move away from transaction-based processes and toward a process focused on
delivering person-centric content. USCIS is updating this Privacy Impact Assessment (PIA) to
describe the additional immigration-related content that Content Management Services will
manage, the new interconnection with Person Centric Identity Services 2 via an Application
Program Interface, and the new data sources included in the Content Management Services’
Content Repository.

Overview
The A-File 3 contains official immigration records of individuals as they pass through or
interact with U.S. immigration and inspection processes. A-Files may include documents related
to law enforcement actions against or involving the individual. USCIS serves as the custodian of
each A-File and its content. The content may come from various sources, including USCIS
systems; other DHS components such as ICE or CBP; the Justice Department’s Executive Office
for Immigration Review proceedings—including proceedings before Immigration Judges and the
Board of Immigration Appeals (BIA); and DOS. USCIS is expanding its use of electronic
immigration records content to gain efficiencies for those business processes that rely on A-Files.
CMS will begin ingesting information obtained by DHS components (ICE and CBP) and by

Application Programming Interface (or API) is a mechanism for two or more systems or services to communicate
with each other and transmit information and data. They also control access to hardware devices and software
functions that an application may not necessarily have permission to use.
2
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE PERSON CENTRIC IDENTITY SERVICES
INITIATIVE, DHS/USCIS/PIA-087 (2022), available at https://www.dhs.gov/uscis-pias-and-sorns.
3
See DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 Fed Reg.
43556 (September 18, 2017), available at https://www.dhs.gov/system-records-notices-sorns. A digital A-File is an
electronic file that stores information about an individual’s immigration history. Not all A-File content is electronic
or online, but RAILS allows USCIS to locate where relevant electronic A-File content is stored or housed.
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external U.S. government agencies (the Justice Department’s Executive Office for Immigration
Review and DOS) to create a more comprehensive immigration record.
CMS is a cloud-based platform that USCIS uses to manage immigration-related content.
Users access CMS immigration-related content through a user interface called STACKS 4 (not an
acronym) or through separate interconnected systems. 5 A variety of USCIS, ICE, and CBP systems
use CMS as a backend/support repository to enhance their effectiveness. CMS supports document
management, imaging, records management, immigration benefit adjudication and enforcement
action workflow, and document-centric collaboration. The CMS platform is an extendible and
highly scalable solution that exposes a robust set of Application Program Interfaces to other
enterprise applications to enable core content-related functions. The goal is to present backend
services that front-end/public-facing applications (e.g., myUSCIS, 6 Freedom of Information Act
(FOIA) Immigration Records Systems (FIRST), 7 Global, 8 and Customer Profile Management
System (CPMS) 9) interact with when content services are required. External application
developers work against standard content Application Program Interfaces published and available
through an enterprise Application Program Interface Gateway. The model for managing this
content aligns with USCIS’ vision to move away from transaction-based processes and toward a
process focused on delivering person-centric content. 10
While storage and retrieval of content is CMS’ most visible function, content services will
also provide rules, behaviors, and policies that can be defined for content types within a given
domain (e.g., case evidence or FOIA responses). Additionally, the underlying content platform
will provide capabilities such as multi-format rendition (e.g., thumbnails or Portable Document
STACKS is a digital file viewing and content management system for official immigration records, part of the
Content Management system directly supporting eProcessing.
5
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR CONTENT MANAGEMENT SERVICES,
DHS/USCIS/PIA-079 (2019 and subsequent updates), available at https://www.dhs.gov/uscis-pias-and-sorns.
6
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR MYUSCIS, DHS/USCIS/PIA-064 (2016), available at
https://www.dhs.gov/uscis-pias-and-sorns.
7
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE FOIA IMMIGRATION RECORDS SYSTEM,
DHS/USCIS/PIA-077 (2019), available at https://www.dhs.gov/uscis-pias-and-sorns.
8
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE USCIS ASYLUM DIVISION, DHS/USCIS/PIA027(d) (2018), available at https://www.dhs.gov/uscis-pias-and-sorns.
9
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE CUSTOMER PROFILE MANAGEMENT SYSTEM,
DHS/USCIS/PIA-060 (2018 and subsequent updates), available at https://www.dhs.gov/uscis-pias-and-sorns.
10
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE PERSON CENTRIC IDENTITY SERVICES
INITIATIVE, DHS/USCIS/PIA-087 (2022), available at https://www.dhs.gov/uscis-pias-and-sorns. Person-centric
refers to aggregating biometric data, biographic information, immigration status, and immigration history into a
single identity profile.
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Format (PDF) renditions), records retention policies, and disposition schedules. The CMS platform
builds upon core managed business capabilities that are extendible and can be used by different
business applications.

Reason for the PIA Update
USCIS is expanding its use of CMS to ingest and manage immigration-related content from
other producers of A-File content, including ICE, CBP, the Justice Department’s Executive Office
for Immigration Review’s electronic Court of Appeals System (ECAS), and DOS. Additionally,
CMS will interface with Person Centric Identity Services via an Application Program Interface
call to generate an A-Number and electronic file resulting from ICE and CBP encounters with an
individual who does not have a physical A-File or an existing paper-based A-File. The electronic
“A-File” is the electronic record of proceedings created to store information related to an
individual’s immigration history. Not all A-File content is electronic or available online, but
RAILS 11 (not an acronym) allows USCIS to locate where relevant electronic A-File content is
stored or maintained. USCIS is updating this Privacy Impact Assessment to describe the additional
immigration-related content CMS will manage, the new interconnection with Person Centric
Identity Services via an Application Program Interface, and the new data sources included in CMS’
Content Repository.
Person Centric Identity Services is an agency-wide effort to use enhanced business
processes and emerging technologies to improve biographic and biometric reliability, accuracy,
and completeness across USCIS and other DHS immigration-related systems. In this effort, a
person’s data is defined as biographic information and biometric attributes that describe a unique
identity. Person data is information related to the individual and not the immigration benefit.
Person Centric Identity Services’ scope includes ingesting personal data in ICE and CBP systems.
Person Centric Identity Services is used by ICE and CBP personnel to assist in identifying an
individual who may have previously filed an immigration benefit with DHS or was encountered
or apprehended by ICE or CBP personnel. Person Centric Identity Services then associates existing
immigration records with that individual. If there are no previous records, Person Centric Identity
Services creates new records, which may include assigning A-Numbers to newly encountered
identities and creating electronic A-Files. These newly created A-Files will be stored as digital
person records within CMS. Person Centric Identity Services does not collect new data elements,
or seek to use personal data in a new manner. It is designed to strengthen linkages of biometric
and biographic information to the correct A-File. Person Centric Identity Services seeks also to
consolidate existing data so that a comprehensive person-centric view of an individual’s

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR RAILS, DHS/USCIS/PIA-075 (2018), available at
https://www.dhs.gov/uscis-pias-and-sorns.
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interactions with DHS is achieved. CMS is comprised of several core components internal to the
system’s operations:
•

Content Repository: The content repository is the centralized repository of digital content.
Digital content may be text (such as electronic documents), multimedia files (such as audio o
o myUSCIS;
o Scan on Demand (SODA); 12
o Customer Profile Management System; and
o FOIA Immigration Records Systems (FIRST).
New data sources include:
o JP Morgan Chase (JPMC) Lockbox; 13
o USCIS Electronic Immigration System (USCIS ELIS); 14
o Global (not an acronym); 15 directly ingested scanned content from Service Centers;
o Case Scanning Portal (CSP); 16
o Iron Mountain (contractor), and other immigration benefit adjudication offices;
o ICE systems such as Enforcement Integrated Database (EID)
o Arrest Guide for Law Enforcement (EAGLE); 17 and
o CBP systems such as e3 Portal; 18
o Unified Secondary (USEC); 19 and
o Unified Immigration Portal (UIP). 20
USCIS is exploring adding content from the ICE Office of the Principal Legal Advisor
(OPLA) Case Management System (OCMS), 21 also known as Principal Legal Advisor

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR INTEGRATED DIGITIZATION DOCUMENT
MANAGEMENT PROGRAM, DHS/USCIS/PIA-003 (2007 and subsequent updates), available at
https://www.dhs.gov/uscis-pias-and-sorns.
13
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR ENTERPRISE GATEWAY AND INTEGRATION
SERVICES, DHS/USCIS/PIA-080 (2019 and subsequent updates), available at https://www.dhs.gov/uscis-pias-andsorns.
14
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR USCIS ELIS, DHS/USCIS/PIA-056 (2018 and subsequent
updates), available at https://www.dhs.gov/uscis-pias-and-sorns
15
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
12

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Network (PLAnet) and will update this Privacy Impact Assessment if that occurs. The
Principal Legal Advisor Network does provide the Office of the Principal Legal Advisor access
to record contents within CMS. However, the Office of the Principal Legal Advisor uses record
contents from CMS in removal proceedings before the Justice Department’s Executive Office
for Immigration Review. In general, items that are considered USCIS records content and
historically managed as paper (e.g., A-File, Receipt File, Temporary File (T-File)) will be
managed in a standard electronic repository that is made available to authenticated systems
through Application Program Interfaces. Until complete digitization is achieved, some content
will be managed in separate physical files supporting the specific business process.
In addition to managing “active” content as part of an ongoing case adjudication, CMS
provides archiving and records management functions. For example, CMS functionality
determines when a record may move to a different storage location (archival) for longer-term
preservation under established record retention requirements. All content (active or archived)
determined to be a part of the agency record copy have disposition schedules to manage longterm retention and eventual destruction or accessioning to the National Archives and Records
Administration (NARA).
•

Content Application Program Interfaces: The Application Program Interface supports
system-to-system interconnections. CMS allows applications to create multiple versions of
single documents and maintains each of these versions as part of an overall record. This
functionality is delivered through secure Application Program Interfaces, where authorization
to these Application Program Interfaces are managed through USCIS approved security

SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE ASYLUM DIVISION, DHS/USCIS/PIA-027 (2009
and subsequent updates), available at https://www.dhs.gov/uscis-pias-and-sorns.
16
The Case Scanning Portal enables the scanning and storing Immigration benefit case files.
17
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS
ENFORCEMENT, PRIVACY IMPACT ASSESSMENT FOR ENFORCEMENT INTEGRATED DATABASE,
DHS/ICE/PIA-015 (2011 and subsequent updates), available at https://www.dhs.gov/privacy-documents-ice.
18
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR THE CBP PORTAL (E3) TO ENFORCEMENT/IDENT,
DHS/CBP/PIA-012 (2012 and subsequent updates), available at www.dhs.gov/privacy-documents-us-customs-andborder-protection.
19
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR CUSTOMS AND BORDER PROTECTION UNIFIED SECONDARY
(USEC), DHS/CBP/PIA-067 (2021 and subsequent updates), available at www.dhs.gov/privacy-documents-uscustoms-and-border-protection.
20
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CUSTOMS AND BORDER PROTECTION,
PRIVACY IMPACT ASSESSMENT FOR UNIFIED IMMIGRATION PORTAL, DHS/CBP/PIA-072 (2022 and
subsequent updates), available at www.dhs.gov/privacy-documents-us-customs-and-border-protection.
21
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. IMMIGRATION AND CUSTOMS
ENFORCEMENT, PRIVACY IMPACT ASSESSMENT FOR OFFICE OF THE PRINCIPAL LEGAL ADVISOR
CASE MANAGEMENT SYSTEM, DHS/ICE/PIA-036 (2013), available at https://www.dhs.gov/privacydocuments-ice.

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mechanisms (e.g., two-way Secure Socket Layer (SSL)). 22 Content that is added and managed
in CMS is managed in several repositories. These Application Program Interfaces are the
cornerstone for integration initiatives internally with Person Centric Identity Services and
externally with ICE and CBP systems.
•

WebUI Components: WebUI components, named STACKS, allow users to create, edit, and
remove case content through a user interface as needed to reflect which records are relevant to
the benefit adjudication or enforcement action (these actions are noted in an audit log). This
also allows users to add notes to documents in a case. External systems may connect directly
to STACKS using a standard URL to access records directly. For example, the RAILS (not an
acronym) system links directly to a particular individual’s records within STACKS.

•

Content Ingestion: Content ingestion facilitates system integration that supports content
ingestion from external content providers (e.g., DOS, ICE, CBP). Additionally, it is used to
ingest legacy content from decommissioned system(s) as part of a migration process (e.g.,
Enterprise Document Management System (EDMS)). 23 Another example of content ingestion
into CMS is the storage of content provided by the Enterprise Print Manager System (EPMS).
The Enterprise Print Manager System is used to generate correspondence, notices, and
documents in support of adjudicative actions. Since this correspondence is considered a part
of the electronic record, the Enterprise Print Manager System will send these electronic files
to CMS, where they will be stored with other information about the specific case.

•

Cryptographic Object Storage Service: The cryptographic object storage service provides
USCIS the capability to store content objects securely in a highly available, highly durable
manner while retaining the ability to delete any individual content object in a manner that
renders it permanently unrecoverable. The solution leverages existing Amazon Web Services
(AWS) infrastructure in conjunction with Federal Information Processing Standard (FIPS)
validated encryption and signing Software Development Kits and a Key Management System
to provide a standardized, secure component that can be used by clients of CMS.

In accordance with USCIS’ mission, USCIS interacts with applicants, petitioners,
beneficiaries, and requestors as well as representatives, interpreters, preparers, sponsors, and civil
surgeons. USCIS has a history of associating paper and electronic case records to individuals using
A-Files. The A-Files and A-Numbers provide a person-centric mechanism for organizing paper
and electronic records. CBP and ICE also rely on and contribute to the immigration records
22
Secure Sockets Layer is a security protocol that provides privacy, authentication, and integrity to Internet
communications. Secure Sockets Layer eventually evolved into Transport Layer Security.
23
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR INTEGRATED DIGITIZATION DOCUMENT
MANAGEMENT PROGRAM (IDDMP), DHS/USCIS/PIA-003 (2007 and subsequent updates), available at
https://www.dhs.gov/uscis-pias-and-sorns.

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contained in the A-File to perform their missions to enforce the nation’s immigration laws at the
border and within the United States. Though USCIS is the custodian of the A-File, both CBP and
ICE create, contribute to, and use A-Files to support DHS’ mission. To streamline the processes
of consuming A-File content data, USCIS and CBP established a connection between CMS and
CBP’s Unified Immigration Portal.
The CBP Unified Immigration Portal provides agencies involved in the immigration
process with a method to view and access certain information from each respective agency from a
single portal in real-time (i.e., as the information is entered into the source systems). The Unified
Immigration Portal aggregates disparate data sources, links related data elements, and visualizes
those data elements in one location using dashboards. In addition to being a visualization tool, the
Unified Immigration Portal serves as a records and information broker for collecting A-File
content created by CBP and ICE for permanent storage in CMS, which ultimately reduces the
reliance on CBP and ICE contributing paper printouts to the paper A-File. By ingesting A-File
content/records sourced into the Unified Immigration Portal, USCIS is advancing a department
guiding principle to create efficiencies across its components to support its mission.
As part of the apprehension and booking process, CBP officers and agents must complete
various charging documents and immigration forms. They collect information from the subject,
and then generate these documents and forms using e3 or Unified Secondary, respectively. These
forms are generated by e3/Unified Secondary 24 and are electronically signed by the processing and
supervisory officers or agents and the individual apprehended by CBP.
USCIS also ingests into CMS A-File record content created during removal proceedings
before the Justice Department’s Executive Office for Immigration Review. Currently, ICE and
CBP upload paper versions of the documents into CMS or interfile such documents in a physical
A-File, which USCIS then manages as a paper record or scans into CMS and manages as an
electronic record. The electronic Court of Appeals System is part of the Justice Department’s
Executive Office for Immigration Review’s overarching information technology modernization
effort to phase out paper-based filing and case processing for court-related records submitted and
retained in electronic format. The electronic Court of Appeals System is now fully implemented
at all immigration courts and the Board of Immigration Appeals to support the entire life cycle of
immigration cases. 25
The DOS also contributes record content to the A-File, principally in visa adjudications
following approval of immigration petitions by USCIS. The DOS transmits visa adjudication
The Unified Secondary system facilitates the documentation of information obtained during the secondary
inspection process to make a decision. Depending on the case disposition, Unified Secondary will recommend
certain charging documents.
25
“The electronic Court of Appeals System is available at all immigration courts and the Board of Immigration
Appeals. Use of the system is mandatory as of February 11, 2022.” https://www.justice.gov/eoir/ECAS.
24

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determinations to CMS through the Immigrant Visa Content Service (IVCS). 26 DOS systems are
integrated only with the Immigrant Visa Content Service and does not directly interface with CMS.
CMS ingests the digitized immigrant visa petition records and stores them as A-File content within
CMS. USCIS and the DOS will continue to improve system-to-system connections to increase the
amount of record content DOS sends to USCIS, to facilitate more efficient exchange of
immigration content between USCIS and DOS, and to enable USCIS to share immigration record
content for authorized purposes relevant to its visa adjudications with the DOS. To that end, the
DOS and USCIS are currently discussing options to directly integrate the DOS content systems,
such as Consolidated Consular Database (CCD), 27 Immigrant Visa Information System (IVIS), 28
and Pre-Immigrant Visa Overseas Technology (PIVOT) 29 with CMS or enable direct access for
DOS personnel to the STACKS interface. Such integrations will be documented in interagency
agreement(s) to include records management procedures and relevant privacy protections. When
these solutions are identified, USCIS will also publish updates to this Privacy Impact Assessment
accordingly.

Privacy Impact Analysis
Authorities and Other Requirements
The authority to collect information in CMS is set forth in the Immigration and Nationality
Act, 8 U.S.C. §§ 1101, 1103, 1304, et seq., and in the implementing regulations found in volume
8 of the Code of Federal Regulations (CFR).
CMS serves as one of USCIS’ repositories for the management of digital and electronic
immigration-related records content. The Alien File, Index, and National File Tracking System of
Records Notice 30 provides information about the collection, maintenance, use, and dissemination
of digital immigration records and supporting documentation in CMS. As new sources are added,
any relevant additional SORNs that describe those new sources will be included in updates to this
Privacy Impact Assessment. The specific System of Records Notices covering the CBP and ICE 31
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR INTEGRATED DIGITIZATION DOCUMENT
MANAGEMENT PROGRAM, DHS/USCIS/PIA-003 (2007 and subsequent updates), available at
https://www.dhs.gov/uscis-pias-and-sorns.
27
See DEPARTMENT OF STATE, PRIVACY IMPACT ASSESSMENT FOR CONSULAR CONSOLIDATED
DATABASE, available at https://www.state.gov/privacy-impact-assessments-privacy-office/.
28
See DEPARTMENT OF STATE, PRIVACY IMPACT ASSESSMENT FOR IMMIGRANT VISA
INFORMATION SYSTEM, available at https://www.state.gov/privacy-impact-assessments-privacy-office/.
29
See DEPARTMENT OF STATE, PRIVACY IMPACT ASSESSMENT FOR PRE-IMMIGRANT VISA
OVERSEAS TECHNOLOGY, available at https://www.state.gov/privacy-impact-assessments-privacy-office/.
30
See DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, 82 Fed Reg.
43556 (September 18, 2017), available at https://www.dhs.gov/system-records-notices-sorns.
31
See DHS/USCIS/ICE/CBP-001 Import Information System, 81 Fed Reg. 48826 (July 26, 2016), available at
https://www.dhs.gov/system-records-notices-sorns.
26

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connected systems’ collection, use, maintenance, and dissemination of information within CMS,
as well as the relevant Justice Department’s Executive Office for Immigration Review and DOS
System of Records Notices from which CMS will ingest immigration-related A-File content is
described in the original CMS Privacy Impact Assessment. 32
CMS is a major application with an Authority to Operate (ATO) and has been accepted
into the DHS Ongoing Authorization program. As part of the Ongoing Authorization program,
CMS’ security and privacy posture is reviewed monthly using risk-based analysis tools to maintain
its ATO.
CMS provides a digital repository service for immigration records relating to immigration
benefit applications, petitions, and actions to enforce the nation’s immigration laws. CMS does
not have a records schedule but the records contained within CMS are subject to National Archives
and Records Administration retention schedules on a form by form, benefit by benefit basis. The
CMS architecture has the capability to apply specific retention schedule requirements to the
records it contains to transfer records for archival storage or to the National Archives and Records
Administration for permanent storage. This capability will be used once USCIS has completed its
review and updates of the various specific retention schedules that govern content currently stored
in CMS.
CMS is not subject to the Paperwork Reduction Act. CMS does not collect information
directly from an individual; no forms associated with this collection. However, CMS stores
electronic USCIS immigration request forms and FOIA/PA forms that the Paperwork Reduction
Act covers. These immigration request forms are further discussed in DHS/USCIS/PIA-061
Benefit Request Intake Process, 33 while the DHS/USCIS/PIA-038 FOIA/PIA Information
Processing System discusses the FOIA/PA form. 34
Characterization of the Information
CMS serves as a repository of digital immigration-related record content. Digital content
may be electronic documents, records, images, videos, or other binary files containing information.
The digital content within CMS may include the following types of information:
•

Immigration request forms;

See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR CONTENT MANAGEMENT SYSTEM,
DHS/USCIS/PIA-079 (2019), available at https://www.dhs.gov/uscis-pias-and-sorns.
33
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT, FOR BENEFIT REQUEST INTAKE PROCESS,
DHS/USCIS/PIA-061 (2016), available at https://www.dhs.gov/privacy.
34
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT, FOR FOIA IMMIGRATION RECORDS SYSTEM,
DHS/USCIS/PIA-077 (2019), available at https://www.dhs.gov/uscis-pias-and-sorns.
32

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•

Immigration-related law enforcement forms;

•

Supplemental documents in support of an immigration request (e.g., birth certificates,
passports, marriage certificates);

•

Supplemental documents in support of an immigration law enforcement action (e.g.,
passports, identity documents);

•

Biometric information provided as evidence in support of an immigration request or
immigration law enforcement action (e.g., photographs, fingerprints, and signatures);

•

Background check enforcement documents (e.g., Identity History Summary, previously
known as the Rap Sheet);

•

USCIS-issued notices and documents (e.g., Request for Evidence (RFE) and Notice of
Intent to Deny (NOID);

•

Notices to Appear, immigration judge orders, and other documents relating to removal
proceedings;

•

Audio and visual recordings (e.g., interviews);

•

Responsive records to FOIA/PA requests; and

•

Other documents (e.g., naturalization certificates, tax returns, labor certifications,
correspondence, court dispositions, and interview notes).

These immigration documents may contain an array of information, including:
•

First, middle, and last name;

•

Alias(es);

•

Sex;

•

Address;

•

Telephone number;

•

Social Security number (SSN);

•

A-Number;

•

Passport Number;

•

Date of birth;

•

Country of birth;

•

Country of citizenship;

•

Vital documents (e.g., birth certificates, passports, marriage certificates);

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•

Biometric information provided as evidence in support of an immigration request or as part
of an immigration law enforcement action (e.g., photographs, fingerprints, and signatures);

•

Enforcement supporting documents; and

•

Other documents (e.g., naturalization certificates; tax returns; labor certifications;
correspondence; court dispositions; interview notes).

Information within CMS is originally derived from the following sources: (1) immigration
requestors, beneficiaries, accredited representatives, attorneys, form preparers, interpreters, and/or
other requestors; (2) internal DHS components; and (3) external entities. Most of the information
in CMS is obtained from the data provided by the immigration requestor or beneficiary on the
completed immigration request form and supporting documentation. CMS obtains data collected
from individuals subject to immigration law enforcement actions or generated during removal
proceedings through the connection with CBP’s Unified Immigration Portal.
As part of the immigration record, CMS may maintain publicly available data from general
internet searches and public social media content not protected by an individual’s privacy settings.
Pursuant to approved Social Media Operational Use Templates, 35 specially trained and authorized
officers may conduct social media assessments 36 that USCIS adjudicators may consider verifying
information provided by the requestor, investigate indications of fraudulent behavior, and identify
threats to national security and public safety discovered while processing immigration benefit
requests. This use of publicly available information is consistent with authority granted to USCIS
by the Immigration and Nationality Act. This information is handled in a manner consistent with
existing USCIS policies and rules of behavior regarding the use of social media information and
publicly available information in adjudicative decision-making.
CMS depends on the accuracy and quality of information received from each source system
or entity. All data is encrypted and is delivered “as is,” except for reformatting to standardize the
representation from the source system to CMS. This process ensures data integrity during
transmission from the connected systems to CMS. Any data accuracy checks are accomplished at
the connected system and are out of the scope of CMS and its security and privacy controls. CMS
cannot and does not provide any assurance that the data it delivers is accurate.

See U.S. DEPARTMENT OF HOMELAND SECURITY, DIRECTIVE NUMBER: 110-01 PRIVACY POLICY
FOR OPERATIONAL USE OF SOCIAL MEDIA (June 8, 2012), available at
https://www.dhs.gov/publication/privacy-policy-operational-use-social-media-directive-110-01.
36
See U.S. DEPARTMENT OF HOMELAND SECURITY, U.S. CITIZENSHIP AND IMMIGRATION
SERVICES, PRIVACY IMPACT ASSESSMENT FOR THE FRAUD DETECTION AND NATIONAL
SECURITY DIRECTORATE, DHS/USCIS/PIA-013(a) (2019 and subsequent updates), available at
https://www.dhs.gov/uscis-pias-and-sorns.
35

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Uses of the Information
CMS serves as a data repository for digital immigration content. The purpose of CMS is to
collect, consolidate, and manage digital information that supports an individual’s immigration
history in a central location. CMS may receive immigration content through secured Application
Program Interfaces from internal and external to DHS. CMS offers access to the digital
immigration related content through two mechanisms: (1) by a user interface called STACKS; and
(2) through an interconnected system.
CMS does not use technology to conduct electronic searches, queries, or analyses to
discover or locate a predictive pattern or anomaly.
DHS components (Headquarters, ICE, and CBP) will be able to access A-File record
content maintained in CMS through the Unified Immigration Portal. ICE and CBP are creators,
contributors to, and users of the A-File record content in CMS through the Unified Immigration
Portal. Other DHS components may be given limited access as permitted by law or policy. Such
access will be documented in Memoranda of Agreement/Memoranda of Understanding or other
interagency agreements.
Notice
All persons are provided general notice of USCIS’s use of CMS and CMS’ connection
with the Unified Immigration Portal through this Privacy Impact Assessment, source system
Privacy Impact Assessments, and other component/agency Privacy Impact Assessments. The
System of Records Notices applicable to the data visualized in the Unified Immigration Portal
provide additional transparency. Moreover, when CBP collects information from persons entering
the United States, CBP provides a form of notice through multiple signs posted in screening or
processing areas at ports of entry. Individuals encountered between ports of entry may not be
provided advance notice but will be provided general notice at the time the information is collected
(e.g., during an inspection and apprehension). In addition, the forms DHS and other federal
agencies use to collect information include, as appropriate, a Privacy Act Statement or Privacy
Notice.
Data Retention by the Project
The official A-File record may take three possible forms: (1) Paper records contained
within a physical A-File; (2) digital or electronic records contained in an electronic system like
CMS or USCIS Electronic Immigration System; or (3) a combination of paper and electronic
formats housed in both a physical A-File and electronic system(s). A-Files are permanent records
maintained in accordance with the National Archives and Records Administration Records
Retention Schedule N1-566-08-11. As such, DHS/USCIS transfers A-Files to the custody of the
National Archives and Records Administration 100 years after the individual’s date of birth.

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Information Sharing
Requests to access immigration records in CMS records content and applications by
USCIS, CBP, and ICE personnel are governed through myAccess, which is a centralized service
used to request access to USCIS systems and accounts. myAccess is maintained by the USCIS
Identity, Credential, and Access Management (ICAM) program, 37 and is the USCIS account role
provisioning and management system that automates the approval process and provides
authorization for user roles and the ability to gain access to USCIS IT systems. Access to
immigration records in CMS by other DHS components through the Unified Immigration Portal
is limited to those with a mission-related need-to-know. Access to CMS by other federal agencies
such as DOS will be governed by separate Memoranda of Understanding or Memoranda of
Agreement and associated Interagency Service Agreements. Records protected under 8 U.S.C. §
1367 and 8 CFR 208.6 will be marked, identified, and handled in accordance with the applicable
confidentiality provisions before the disclosure of information. If there is a valid need to share the
CMS data externally, it must be done in accordance with the A-File System of Records Notice and
DHS policy.
Redress
Individuals may seek access to their USCIS records by filing a Privacy Act or FOIA
request. Only U.S. citizens, Lawful Permanent Residents (LPR), and covered persons from a
covered country under the Judicial Redress Act (JRA) may file a Privacy Act request. Individuals
not covered by the Privacy Act or the Judicial Redress Act may still obtain access to records
consistent with a FOIA request unless disclosure is prohibited by law or if the agency reasonably
foresees that disclosure would harm an interest protected by an exemption. If an individual would
like to file a Privacy Act or a FOIA request to view their USCIS record, they may file the request
electronically
at
https://www.uscis.gov/records/request-records-through-the-freedom-ofinformation-act-or-privacy-act or mail the request to the following address:
National Records Center
Freedom of Information Act (FOIA)/Privacy Act Program
P. O. Box 648010
Lee’s Summit, MO 64064-8010
Some information requested may be exempt from disclosure under the Privacy Act or
FOIA request because information may contain sensitive information law enforcement, the release
of which could compromise ongoing criminal investigations. Further information about the
Privacy Act and FOIA requests for USCIS records can be found at https://www.uscis.gov.
See U.S. DEPARTMENT OF HOMELAND SECURITY, PRIVACY IMPACT ASSESSMENT FOR THE
PERSONAL IDENTITY VERIFICATION (PIV) MANAGEMENT SYSTEM, DHS/ALL/PIA-014 (2006 and
subsequent updates), available at https://www.dhs.gov/privacy-documents-department-wide-programs.
37

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Auditing and Accountability
In accordance with DHS security guidelines, CMS has auditing capabilities that log user
activities. CMS tracks all user actions via domain security audit logs to identify audit information
by user identification, network terminal identification, date, time, and data accessed. CMS employs
auditing measures and technical safeguards to prevent the misuse of data. In addition to general
users of A-File record content, some CMS users have job duties that require them to design,
develop, and optimize the system. These users perform this work under supervisory oversight. In
addition, CMS has internal audits separate from the domain security audits; therefore, a double
layer of audit trails exists. Furthermore, CMS is housed in the Federal Risk and Authorization
Management Program (FedRAMP)-approved Amazon Web Services cloud environment, at a
moderate confidentiality that allows USCIS to host personally identifiable information. Amazon
Web Services US East/West is a multi-tenant public cloud designed to meet a wide range of
regulatory requirements, including Government compliance and security requirements. FedRAMP
is a U.S. Government wide program that delivers a standard approach to the security assessment,
authorization, and continuous monitoring for cloud services.

Responsible Official
Angela Washington
USCIS Chief Privacy Officer
U.S. Department of Homeland Security
[email protected]
(202) 570-8327

Approval Signature
Original, signed copy on file at the DHS Privacy Office
________________________________
Deborah Fleischaker
Chief Privacy Officer (A)
U.S. Department of Homeland Security
[email protected]

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APPENDIX D: DHS and External System Interconnections
*This Appendix mirrors Appendix D in the original CMS Privacy Impact Assessment

Below are the DHS and External System Interconnections with CMS
Connection
Relationship

System

Information

Connection Type

Connection
Subtype

CMS Receives
from

Central
Index
System 2
(CIS2)

Person biodata and sensitivity status
Violence Against Women Act
(VAWA), Section 1367)

Direct Connection

Application
Program Interface
(API) - Gateway

CMS Sends to

CIS2

Person metadata (Alien Number)

Direct Connection

API - Gateway

Direct Connection

API - Gateway

Direct Connection

API - Gateway

Direct Connection

API - Gateway

Direct Connection

API - Gateway

CMS Receives
From

CMS Sends to

CMS Receives
From
CMS Sends To

Computer
Linked
Application
Management Case Decision Metadata
System
(CLAIMS) 3
LAN
API Confirmation / Error
CLAIMS 3
Responses; Case and Content
LAN
Metadata
Customer
Profile
Migration of CPMS Data to CMS
Management
Repository; Content and Metadata
System
(CPMS)
API Confirmation / Error
CPMS
Responses; Content and Metadata

Kafka Enterprise
Messaging
(USCIS only)
Kafka Enterprise
Messaging
(USCIS only)

CMS Receives
From

Case
Scanning
Portal (CSP)

Scanned/digitized cases and content

Direct Connection

CMS Sends To

CSP

Confirmation/error responses

Direct Connection

CMS Receives
From

Data and
Business
Intelligence
Services
(DBIS)

Case decision data related to closed
cases received from Iron Mountain

Direct Connection

API - Gateway

CMS Sends To

DBIS

Case metadata

Direct Connection

API - Gateway

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CMS Receives
From

Enterprise
Document
Migration of EDMS A-File and
Management Case content and metadata to CMS
System
Repository
(EDMS)

Direct Connection

API - Gateway

CMS Sends To

EDMS

Direct Connection

API - Gateway

CMS Receives
From

Electronic
Print
Correspondence related to Benefit
Management
Application Cases
System
(EPMS)

CMS Sends to

EPMS

Kafka and API Confirmation / Error
Responses

Direct Connection

CMS Receives
From

Fraud
Detection &
National
Security
Next
Generation
(FDNS
NexGen)

Content and Metadata

Direct Connection

API - Gateway

CMS Sends To

FDNS
NexGen

Direct Connection

API - Gateway

CMS Receives
From

Fraud
Detection &
National
Security
Data System
(FDNS-DS)

API Confirmation / Error
Responses; Encounter Content and
Metadata
Migration of FDNS Data to CMS
Repository; Content and Metadata

Direct Connection

API - Gateway

CMS Sends to

FDNS-DS

API Confirmation / Error Responses

Direct Connection

API - Gateway

CMS Receives
From

FOIA
Immigration
Records
System
(FIRST)

Content and Metadata

Direct Connection

API - Gateway

CMS Sends To

FIRST

Content and Metadata

Direct Connection

API - Gateway

CMS Receives
From

Global
Asylum

Case Decision Metadata

Direct Connection

API - Gateway;
Kafka Enterprise

API Confirmation / Error Responses

Direct Connection

API - Gateway;
Kafka Enterprise
Messaging
(USCIS only)
API - Gateway;
Kafka Enterprise
Messaging
(USCIS only)

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Messaging
(USCIS only)

CMS Sends to

Global
Asylum

API Confirmation / Error Reponses;
Case and Content Metadata

Direct Connection

CMS Receives
From

Iron
Mountain

Scanned/digitized persons, cases and
content

Indirect
Connection

API - Gateway;
Kafka Enterprise
Messaging
(USCIS only)
External FILE
(Iron Mountain)

Confirmation/error responses

Indirect
Connection

External FILE
(Iron Mountain)

Migration of IVCS data to CMS
Repository

Direct Connection

API - Gateway

Scanned/digitized cases and content

Indirect
Connection

External
Messaging
(ActiveMQ)

CMS Sends To
CMS Receives
From

CMS Receives
From

Iron
Mountain
Immigrant
Visa
Content
Service
IVCS
JP Morgan
Chase
(JPMC)
Lockbox

External
Messaging
(ActiveMQ)
API - Gateway;
Kafka Enterprise
Messaging
(USCIS only)
API - Gateway;
Kafka Enterprise
Messaging
(USCIS only)

CMS Sends To

JPMC

Confirmation/reconciliation/error
responses

Indirect
Connection

CMS Receives
From

MyUSCIS

I-539 Forms and Evidence, I-589
Forms and Evidence

Direct Connection

CMS Sends to

MyUSCIS

Kafka Confirmation / Error
Responses

Direct Connection

CMS Receives
From

Person
Centric
Query
Service
(PCQS)

Person Metadata

Direct Connection

API - Gateway

CMS Sends to

PCS

API Confirmation / Error Responses

Direct Connection

API - Gateway

RAILS

Notification of Digitized Cases and
A-Files

Direct Connection

Kafka Enterprise
Messaging
(USCIS only)

CMS Sends to

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CMS Receives
From
CMS Receives
From
CMS Sends To

Scan on
Demand
Application
(SODA)
CBP’s
Unified
Immigration
Portal (UIP)
UIP

Digitized A-Files

Direct Connection

Kafka Enterprise
Messaging
(USCIS only)

A-File Create Messages, Alien
Encounter Forms and Evidence

Direct Connection

API - Gateway

API Confirmation / Error
Responses; Encounter Content and
Metadata

Direct Connection

API - Gateway