WPF comments on the DHS External Biometric Records database

The World Privacy Forum has submitted detailed comments on the US Department of Homeland Security’s External Biometric Records database (EBR database), which DHS describes as a large biometric and demographic database drawn from foreign and domestic sources. WPF has a number of concerns about the proposal, including that the EBR database is slated to be exempted from multiple provisions of the Privacy Act. WPF has additional procedural concerns regarding biometrics and fairness.

The EBR database is primarily a database to be used for law enforcement purposes, among some other purposes, including national security, immigration screening, border enforcement, intelligence, national defense, background investigations relating to national security positions, credentialing, and certain positions of public trust.

In addition to traditional biometric and demographic data, the External Biometric Records database will also include diverse commentary and also derivative analysis, which will not have been collected directly from individuals. Access to the data, the accuracy of data, and many other rights typically associated with data held by the US government under the Privacy Act of 1974 do not apply to the EBR database due to the exemptions DHS has proposed.

One of the more serious concerns WPF has relates to a proposed routine use of the database that would allow DHS to publicly release biometrics, including DNA. WPF is requesting DHS to agree to either greatly narrow its ability to release DNA publicly, or drop DNA from inclusion in the routine uses.

Related Documents:

WPF Comments on the External Biometric Records Database 24 May, 2018