Pta

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
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
PIA@hq.dhs.gov
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, pia@hq.dhs.gov
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:

G-28; G-28I

Form Title:

Notice of Entry of Appearance as Attorney or Representative;
Notice of Entry of Appearance as Attorney in Matters Outside the
Geographical Confines of the United States

Component:

U.S. Citizenship and
Immigration Services
(USCIS)

Office:

Office of Chief Counsel

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Form G-28, Notice of Entry of Appearance as Attorney or
Representative
Form G-28I, Notice of Entry of Appearance as Attorney in Matters
Outside the Geographical Confines of the United States
OMB Control
1615-0105
OMB Expiration
March 31, 2018
Number:
Date:
Collection status:
Revision
Date of last PTA (if
March 19, 2014
applicable):

Name:
Office:

PROJECT OR PROGRAM MANAGER
Catherine M. O’Connell
Office of Chief Counsel
Title:
Disciplinary Counsel

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Phone:

Name:
Office:
Phone:

313-926-4212

Email:

Catherine.OConnell@uscis.d
hs.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Kerstin Jager
Regulatory Coordination
Title:
Adjudication Officer
Division
202-213-4211
Email:
Kerstin.A.Jager@uscis.dhs.g
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.
Form Revision
USCIS is submitting the Form G-28/28I PTA to formally document the revision of the
Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative, and
Form G-28I, Notice of Entry of Appearance as Attorney in Matters Outside the Geographic
Confines of the United States, which includes, standard form language such as, USCIS
Online Account Number, Receipt Number, Contact Information of Attorney or Accredited
Representative, and Contact Information of Applicant
Overview
Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative
DHS has designated Form G-28 as the document on which attorneys and accredited
representatives provide information to establish their eligibility to appear for and act on
behalf of an applicant, petitioner, or respondent in immigration matters. An attorney or
accredited representative appearing before DHS must file Form G-28 in each case. USCIS,
CBP, and/or ICE will only recognize Form G-28 for the appearance of an attorney or
accredited representative once the applicant, petitioner, requestor, or respondent has
completed, signed, and filed Form G-28.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

A beneficiary of a petition is not a recognized party in a proceeding before USCIS under 8
CFR 103.2(a)(3). USCIS, CBP, and/or ICE will recognize Form G-28 until the conclusion
of the matter for which it is entered. An applicant, petitioner, requestor, or respondent
must file a new Form G-28 with the Administrative Appeals Office when filing an appeal
to that office on Form I-290B, Notice of Appeal or Motion.
Form G-28I, Notice of Entry of Appearance as Attorney in Matters Outside the
Geographical Confines of the United States
An attorney admitted to the practice of law in a country other than the United States who
seeks to appear before DHS in a matter outside the geographical confines of the United
States must file Form G-28I in each case. Form G-28I must be properly completed and
signed by the applicant, petitioner, or respondent to authorize representation for the
appearance to be recognized by USCIS, CBP, and ICE. Under 8 CFR 103.2(a)(3), a
beneficiary of a petition is not a recognized party in a proceeding before USCIS. Form G28I will be recognized by USCIS, CBP, or ICE until the conclusion of the matter for which
it was entered.

Relevant Information Technology
G-28/G-28I is processed along with a principal form or any other form on which the alien
is being represented. This form is placed in the A-file of the individual who is
represented. It is also placed in the receipt 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.
The G-28 is based on DHS having the authority to discipline attorneys who represent
clients in immigration matters before DHS. The authority for that is the Secretary of
Homeland Security’s (Secretary) authorities under the Homeland Security Act of 2002,
Public Law 107-296, section 102, 116 Stat. 2135, 6 U.S.C. 112, and the Immigration and
Nationality Act of 1952, as amended (INA or Act), section 103(a), 8 U.S.C. 1103(a), to
administer and enforce the immigration and naturalization laws and to discharge other
related DHS functions. Under such authorities, DHS regulates immigration practitioners
appearing or seeking to appear before U.S. Citizenship and Immigration Services (USCIS),
U.S. Immigration and Customs Enforcement (ICE), and U.S. Customs and Border
Protection (CBP).

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

8 CFR 103.2 and 292.1 allow persons entitled to representation to be represented in
matters before U.S. Citizenship and Immigration Services (USCIS), U.S. Immigration and
Customs Enforcement and U.S. Customs and Border Protection, Department of Homeland
Security (DHS). Representatives must file an appearance on the appropriate form in
each case. 8 CFR 292.4.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?
b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

☒ Yes
☐ No
☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

c. Who will complete and
submit this form? (Check
all that apply.)

☒ The record subject of the form (e.g., the
individual applicant).
☒ Legal Representative (preparer, attorney,
etc.).
☒ Business entity.
If a business entity, is the only
information collected business contact
information?
☒ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.

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, pia@hq.dhs.gov
www.dhs.gov/privacy

☐ 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: https://myaccount.uscis.dhs.gov/
(At this link, representatives can set up a USCIS
Online Account, which provides access to forms
that are available for e-filing. A Form G-28 can be
submitted electronically along with any primary
form that is available for e-filing.)

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 G-28, Notice of Entry of Appearance as Attorney or Representative
Information Collected About the Attorney or Accredited Representative
 Last name
 First name
 Middle name
 Name of Law Firm
 Law Firm Address
 Daytime Telephone Number
 Mobile Telephone Number
 Email address (if any)
 USCIS Online account number (if any)
 Attorney bar number (if any)
 States of admission
 Eligibility information for Attorney or Accredited Representative
 Licensing Authority
 Name of Recognized Organization
 Date of Accreditation
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy


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Name of Law Student or Law Graduate working under the direct supervision
Appearance related to previous immigration matters
U.S. Citizenship and Immigration Services (USCIS) form numbers
U.S. Immigration and Customs Enforcement (ICE) and specific matter in which
appearance is entered
U.S. Customs and Border Protection (CBP) and specific matter in which
appearance is entered
Appearance as attorney or accredited representative at the request of
Signature of Attorney or Accredited Representative
Signature of Law Student or Law Graduate
Date of Signature

Information Collected About the Applicant, Petitioner, Requestor, or Respondent
 Last name
 First name
 Middle name
 Mailing address
 Name of company or organization (if applicable)
 USCIS Online account number (if any)
 A-Number (if any)
 Receipt number (if any)
 Daytime Telephone Number
 Mobile Telephone Number (if any)
 Email Address
 Mailing Address of Applicant, Petitioner, Requestor, or Respondent
 Consent to Representation and Release of Information
 Signature of Applicant, Petitioner, Requestor, or Respondent
 Request to receive original notices/and or secure identity documents directly or
sent to the attorney of record or accredited representative
 Date of Signature
Form G-28I, Notice of Entry of Appearance as Attorney in Matters Outside the
Geographical Confines of the United States
Information About Attorney
 USCIS Online Account number (if any)
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

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Last Name
First Name
Middle Name
Name of Law Firm (if Applicable)
Attorney Address
Daytime Telephone Number
Mobile Telephone Number (if any)
Email Address (if any)
Eligibility Information for Attorney
Licensing Authority
Bar Number (if applicable)
Notice of Appearance as Attorney Admitted to Practice Outside the United States
U.S. Citizenship and Immigration Services and form numbers
U.S. Immigration and Customs Enforcement (ICE) and specific matter in which
appearance is entered
U.S. Customs and Border Patrol (CBP) and specific matter in which appearance is
entered
Appearance as Attorney at the request of the applicant, petitioner, or respondent
(ICE, CBP)
Signature of Attorney
Date of Signature

Information About Applicant, Petitioner, or Respondent
 Last Name
 First Name
 Middle Name
 Name of Company or Organization (if applicable)
 USCIS Online Account Number (if any)
 Alien Registration Number (if any)
 Receipt Number (if any)
 Daytime Telephone Number
 Email Address (if any)
 Mailing Address of Applicant, Petitioner, or Respondent
 Consent to Representation and Release of Information

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy


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
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Request to receive original notices and/or secure identity documents directly or
sent to the attorney of record
Request for DHS to send any original notice containing Forms I-94, ArrivalDeparture Record, to U.S. mailing address
Signature of Applicant, Petitioner or Respondent
Date of Signature

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
☒ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ 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.
8 CFR 103.2 and 292.1 allow persons entitled to representation to be represented in
matters before U.S. Citizenship and Immigration Services (USCIS), U.S. Immigration and
Customs Enforcement and U.S. Customs and Border Protection, Department of Homeland
Security (DHS). Representatives must file an appearance on the appropriate form in
each case. For USCIS to accurately identify the person on whose behalf the appearance
is being entered, USCIS collects the person’s Alien Registration Number, along with other
personally identifiable information. Collecting the A-Number along with other PII
ensures that the representative entering an appearance is provided with information
only pertaining to the person being represented, and not with information related to a
different person.

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.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

The data collected on Forms G-28 and G-28I is used by DHS to determine eligibility of the
individual to appear as a representative. The information collected via these forms,
which allows a person to represent someone else in front of USCIS, is not available
anywhere else and is unique to these forms. If the representative is eligible, the form is
filed with the case and the information is entered into DHS systems for whatever type of
application or petition it may be.

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.
There is a Privacy Notice in the corresponding
form instructions.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
G-28/G-28I is processed along with a principal
completed IC/forms?
form or any other form on which the applicant,
petitioner, or respondent is being represented.
This form is placed in the A-file of the individual
who is represented. It is also placed in the receipt
file.
☒ Electronic. Please describe the IT system that will
store the data from the form.
G-28 information can be provided in connection
with a USCIS form that is available for electronic
filing. Information for an e-filed G-28 is stored in
the USCIS Electronic Immigration System (ELIS).
(The G-28I cannot be e-filed.)
G-28 data can also be stored electronically in
CLAIMS 3, CLAIMS 4, and RAPS/APSS.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Scanned G-28 and G-28I forms may be stored in
the Electronic Data Management System (EDMS)
when they are part of an A-file that has been digitized.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
Information from Form G-28 is manually keyed
into CLAIMS 3, CLAIMS 4, ELIS and RAPS/APSS.
☒ Automatically. Please describe.
Form G-28 data provided by the respondent is
automatically entered into USCIS ELIS when the
form is submitted via e-filing.

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.
Depending on the system being searched, a user
may search by A-Number, Name, and/or USCIS
Online Account Number,
☐ By a non-personal identifier. Please describe.
Click here to enter text.
A-File: N1-566-08-11
CLAIMS 3: DAA-0566-2016-0013; DAA-0566-20160009
CLAIMS 4: DAA-0566-2017-0017
RAPS/APSS: N1-563-04-06/ N1-563-04-07
ELIS: N1-566-12-05; N1-566-11-02
EDMS: N1-566-08-17
All Form G-28 and G-28I are retained and disposed
of/deleted according to the retention schedules listed
above.

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

e. How do you ensure
that records are
disposed of or deleted
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, pia@hq.dhs.gov
www.dhs.gov/privacy

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.
Information is shared with operational programs across DHS to inform them
of representation. Information may be shared with Fraud Detection and
National Security Directorate or Homeland Security Investigations for the
purposes of conducting investigations or, in attorney discipline cases,
preliminary inquiries.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Information may be shared with state bar associations, attorney disciplinary
authorities and local law-enforcement agencies that are investigating
practitioners, persons, or entities who may be committing improper or
fraudulent acts.
☐ 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, pia@hq.dhs.gov
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:

August 17, 2017

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.)

September 13, 2017
☒ 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 USCIS Office of Privacy recommendation is to designate Form G-28/28I as
privacy sensitive with coverage under the following privacy compliance
documentation:
PIA








DHS/USCIS/PIA-015 Computer Linked Application Information Management
System (CLAIMS 4) Update, which covers the electronic storage and processing of G28 only
DHS/USCIS/PIA-016 Computer Linked Application Information Management
(CLAIMS 3) and Associated Systems, which covers data elements from the Form G28 entered into CLAIMS 3
Forthcoming myUSCIS PIA, which covers the Form G-28 submission and processing
via the USCIS Online account
DHS/USCIS/PIA-056 ELIS, which covers the storage of information from Form G-28
entered into ELIS when the form is submitted via e-filing
DHS/USCIS/PIA-027(c)- USCIS Asylum Division, which covers the electronic storage
and processing of the G-28 in RAPS/APSS

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy







DHS/USCIS/PIA-003(b)- Integrated Digitization Document Management Program
(IDDMP), which covers the digitization and storage of G-28 and G-28I forms stored
in the Electronic Data Management System (EDMS)DHS/USCIS/PIA-007(b)
Domestically Filed Intercountry Adoptions and Petitions, which covers attorney and
representative information used to process intercountry adoptions
DHS/USCIS/PIA-051 Case and Activity Management for International Operations
(CAMINO), which covers the processing of the Form G-28 along with the Form I290B
DHS/USCIS/PIA-013(a) Fraud Detection and National Security Data System (FDNSDS), which covers the information from the Form G-28 that may be shared with
FDNS during the adjudicative and administrative investigation process

SORN
 DHS/USCIS/ICE/CBP-001- Alien File, Index, and National File Tracking System of
Records, which covers the collection, use, and storage of the form stored in the A-file
and Receipt file
 DHS/USCIS-007 Benefits Information System of Records, which covers the
collection, use, and storage of data elements USCIS collects from the attorney or
accredited representative, applicant, petitioner, requestor, or respondent
 DHS/USCIS- 010 Asylum Information and Pre-Screening System of Records, which
covers the collection, use and storage of data elements collected from attorneys and
accredited representatives stored in CLAIMS 3 and RAPS/APSS
 DHS/USCIS-005 Inter-Country Adoptions Security , which covers the collection, use,
and storage of data elements (biographical information) collected from attorneys
and representatives that facilitate the adoption process so that USCIS can track and
verify those entities that are authorized to participate in the adoption process
 DHS/USCIS-017 Refugee Case Processing and Security Screening Information, which
covers the collection, use and storage of data elements (biographical information)
collected from attorneys and representatives who complete applications on behalf
of refugee applicants
 DHS/USCIS-006 Fraud Detection and National Security Records, which covers the
collection, use, and storage of the representative and preparer information
maintained in the G-28

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

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

Kameron Cox

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

1150078
September 20, 2017
September 20, 2020

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 approved this ICR/Form.

Date IC/Form Approved September 19, 2017
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
New e(3) statement is required.
Statement:
New Privacy Notice is Required
PTA:
No system PTA required.
Click here to enter text.
PIA:
PIA update is required.
If covered by existing PIA, please list:
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

DHS/USCIS/PIA-013(a) Fraud Detection and National Security Data
System (FDNS-DS); DHS/USCIS/PIA-015(b) Computer Linked
Application Information Management System (CLAIMS 4) Update;
DHS/USCIS/PIA-016(a) Computer Linked Application Information
Management System (CLAIMS 3) and Associated Systems;
DHS/USCIS/PIA-056 USCIS Electronic Immigration System;
DHS/USCIS/PIA-027(c) USCIS Asylum Division; DHS/USCIS/PIA-003(b)
Integrated Digitization Document Management Program;
DHS/USCIS/PIA-007(b) Domestically Filed Intercountry Adoptions
Applications and Petitions; DHS/USCIS/PIA-051 Case and Activity
Management for International Operations (CAMINO); DHS/USCIS/PIA061 Benefit Request Intake Process
If a PIA update is required, please list:
Forthcoming myUSCIS PIA
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/USCIS/ICE/CBP-001 Alien
File, Index, and National File Tracking System of Records, September 18,
2017, 82 FR 43556; DHS/USCIS-007 Benefits Information System,
October 19, 2016 81 FR 72069; DHS/USCIS-010 Asylum Information
and Pre-Screening System of Records, November 30, 2015, 80 FR 74781;
DHS/USCIS-005 Inter-Country Adoptions Security, November 8, 2016,
81 FR 78614; DHS/USCIS–017 Refugee Case Processing and Security
Screening Information System of Records, October 19, 2016, 81 FR
72075; DHS/USCIS-006 Fraud Detection and National Security Records
(FDNS) August 8, 2012, 77 FR 47411
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCIS is submitting this PTA to formally document the revision of the Form G-28 and G-28I
that includes the addition of the USCIS online account number, receipt number, contact
information of attorney or accredited representative, and contact information of applicant.
The DHS Privacy Office (PRIV) finds that Forms G-28 and G-28I are a privacy sensitive
information collection and a PIA is required because the forms collects PII from members
of the public. PRIV agrees with USCIS about coverage under the following PIAs:
DHS/USCIS/PIA-061 Benefit Request Intake Process, which covers the collection and use of
all benefit request forms, to include Form G-28 and G-28I. DHS/USCIS/PIA-015 CLAIMS 4
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

covers the electronic storage and processing of Form G-28, DHS/USCIS/PIA-016 CLAIMS 3
covers data from Form G-28 entered into CLAIMS 3, and DHS/USCIS/PIA-027(c) USCIS
Asylum Division covers the electronic storage and processing of data from Form G-28
within RAPS/APSS. DHS/USCIS/PIA-007(b) Domestically Filed Intercountry Adoptions and
Petitions, and DHS/USCIS/PIA-051 CAMINO assess the privacy risks of processing Form G28 information as part of the adjudicative process. DHS/USCIS/PIA-056 ELIS covers the
storage of information from Form G-28 entered into ELIS when the form is submitted via efiling on USCIS online. DHS/USCIS/PIA-003(b) IDDMP covers the digitization and storage
of G-28 and G-28I forms stored in the Electronic Data Management System (EDMS).
DHS/USCIS/PIA-013(a) FDNS covers the sharing of attorney information for cases
involving fraud or national security concerns on the part of the applicant or the attorney.
Finally, an update is required for the myUSCIS PIA to cover the Form G-28 submission and
processing via the USCIS Online account. As the online submission process for myUSCIS is
the same as USCIS ELIS, the ELIS PIA is able to provide interim coverage.
PRIV finds that a SORN is required because information collected on Forms G-28 and G-28I
can be retrieved by a unique identifier. The forms are covered by DHS/USCIS/ICE/CBP001- A-File, which covers the collection, use, and storage of the form stored in the A-file
and Receipt file; DHS/USCIS-007 BIS, which covers the collection, use, and storage of the
form and data elements USCIS collects in processes outside of the A-File except for Refugee
and Asylum applications. DHS/USCIS-005 Inter-Country Adoptions Security provides
additional coverage for data collected from attorneys and representatives as part of the
adoption process. DHS/USCIS- 010 Asylum and DHS/USCIS-017 Refugee Case Processing
cover the collection, use and storage of data elements collected from attorneys and
accredited representatives stored in CLAIMS 3 and RAPS/APSS. DHS/USCIS-006 FDNS
SORN covers the collection, use, and storage of form G-28 information for purposes of
aiding investigations into fraud, attorney discipline, and national security.
This program contemplates sharing attorney and representative PII with local law
enforcement state bar associations in cases of suspected fraud or misconduct. This sharing
is permitted under Routine Use G of the A-File, BIS, Adoption, Asylum, Refugee, and FDNS
SORNs. This sharing is compatible with the purpose of the SORNs because it facilitates the
administration, and ensures the integrity, of the legal immigration system.
PRIV recommends that when USCIS makes updates to the A-File SORN, BIS SORN, Asylum
SORN, and Refugee SORN it include the myUSCIS account # for attorneys/representatives
as a data element in their respective categories of records and retrieval of records.
PRIV finds that a Privacy Notice is required because Forms G-28 and G-28I collect PII from
individuals, including non-US persons, which will be entered into a system of records. PRIV
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U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

concludes that the Privacy Notice USCIS submitted concurrently with this PTA provides
adequate notice.
This PTA will expire in one year.

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