US Department of Homeland Security

Press Announcement: World Privacy Forum files comments to DHS regarding the Border Crossing Information System; Some proposed routine uses of the system directly contravene the Privacy Act of 1974

Border Crossing Information System, DHS — The World Privacy Forum submitted public comments today to the Department of Homeland Security regarding its proposed Border Crossing Information System. The BCI system would set up a database of all border crossings via car, rail, air and other means, including collecting identifiable data on the activities of American citizens. Information collected includes biographical and other information such as name, date of birth, gender, a photograph, itinerary information, and the time and location of the border crossing. The WPF comments focus entirely on the proposed Routine Uses of the system. As currently written, the DHS proposal contains some Routine Uses that directly contravene the Privacy Act of 1974 and are illegal. Other Routine Uses are overbroad and vague, and still others contravene guidance from the Office of Management and Budget (OMB). One example of an overbroad Routine Use is Routine Use J, which will allow DHS to release data collected for the Border Crossing Information System for hiring decisions or contract awards. This information may be requested by Federal, state, local, tribal, foreign, or international agencies. Another Routine Use, G, impermissibly duplicates and weakens the Privacy Act’s condition of requirement for notice when information is disclosed in certain circumstances.

Public Comments: August 2008 – Border Crossing Information, System of Records Notice, DHS-2007-0040

The World Privacy Forum filed comments regarding DHS’s proposed Border Crossing Information system of records, finding that many of the Routine Uses proposed for the system were impermissible and illegal under the Privacy Act of 1974. The comments focus on the Routine Uses, rather than the system itself.

World Privacy Forum and Electronic Frontier Foundation File Public Comments on REAL ID

REAL ID | National ID — The World Privacy Forum and the Electronic Frontier Foundation (EFF) filed joint comments with the Department of Homeland Security about the proposed national ID system, REAL ID. The comments discuss the substantial flaws in the proposed REAL ID system including concerns about the overall structure of the program, the cards, the databases attached to the cards, the lack of controls on “function creep,” the possibilities for discrimination, the potential for increased risk of identity theft, issues related to potential gaps in coverage for recipients on Federal programs, among other issues.

Public Comments: May 2007 – REAL ID …. Joint Comments …. World Privacy Forum and Electronic Frontier Foundation File Public Comments on REAL ID

The World Privacy Forum and the Electronic Frontier Foundation (EFF) filed joint comments with the Department of Homeland Security about the proposed national ID system, REAL ID. The comments discuss the substantial flaws in the proposed REAL ID system including concerns about the overall structure of the program, the cards, the databases attached to the cards, the lack of controls on “function creep,” the possibilities for discrimination, the potential for increased risk of identity theft, issues related to potential gaps in coverage for recipients on Federal programs, among other issues. Read the comments (PDF). See the EFF REAL ID pages for background about REAL ID.

Stop REAL ID

REAL ID — REAL ID is a national ID card program. Currently, the Department of Homeland Security is accepting public comments on the REAL ID plan. Comments will be accepted until Tuesday, May 8. The World Privacy Forum has joined with a large coalition of groups to solicit public comments on REAL ID; to file comments, please visit the Speak Out Against REAL ID coalition page for more information. http://www.privacycoalition.org/stoprealid/