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CBP Publishes Privacy Evaluation Report of the Traveler Verification Service

CBP deployed cyber enhanced technology that facilitates audit tracking, logging, and enhanced encryption to further protect image data; restricted the use of removable media devices on systems collecting images; updated contractual, policy, and security requirements; and implemented enhanced usage of Data Loss Protection and encryption practices across the enterprise.

As part of its continuing effort to promote organizational accountability and transparency, the U.S. Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP), Office of Field Operations (OFO), and the Office of Privacy and Diversity (PDO) released a report of the Traveler Verification Service (TVS) in support of CBP’s Biometric Entry-Exit (BE-E) Program.

CBP built the Traveler Verification Service – a facial biometric matching system — to automate the identity verification process to further secure and enhance travel while advancing the Biometric Entry-Exit mandate.

In FY2018, CBP published the TVS Privacy Impact Assessment (PIA) which directed the PDO to conduct a privacy evaluation of the BE-E Program’s use of the biometric facial comparison technology, TVS.

The 2022 report has found that OFO and the Office of Information Technology were utilizing TVS in support of the BE-E Program in a manner that is compliant with requirements in current privacy compliance documentation, DHS/CBP policy, and U.S. law.

Commercial partners are not permitted to retain or share photos that are captured in support of CBP’s identity verification operations. At the time of the report, CBP had conducted six security assessments of commercial partners’ biometric exit solutions. Each review has confirmed the commercial partner is not storing photos after matching with TVS occurs. Though the TVS-partners initiative indicates that commercial partners may collect separate photographs consistent with their contractual relationships with the travelers for commercial purposes, there are no current commercial partners that have communicated an intent to collect images for their own uses.

To mitigate risks associated with biases against race, ethnicity, age, and gender present in various biometric facial comparison algorithms, the National Institute of Standards and Technology conducted an evaluation of the algorithms used. The analysis found that there are currently no detectable biases within the algorithm that CBP employs. The assessment also found that match rates have continued to improve over time, with images collected from individuals from all regions of the globe performing relatively equally, between 98.1% and 99.6% match rates. Similar improvements were found with regard to age, though middle-aged people (between 26 and 65 years of age) tend to have slightly higher match rates. Despite the minimally lower match rate for young (age 14-25) and old (age 66-79) individuals, age bias for CBP’s algorithm is considered negligible, with matches less likely to occur 0.3% and 0.1% of the time for those travelers respectively. The assessment also indicated that algorithm bias related to gender was negligible, with women only 0.04% more likely to match than men. 

The report also notes that in the wake of the 2019 breach, CBP implemented additional safeguards to ensure the security of biometrics systems and information, strengthening the agency’s security posture where sensitive data is concerned. Specifically, CBP deployed cyber enhanced technology that facilitates audit tracking, logging, and enhanced encryption to further protect image data; restricted the use of removable media devices on systems collecting images; updated contractual, policy, and security requirements; and implemented enhanced usage of Data Loss Protection and encryption practices across the enterprise. CBP also took steps to strengthen privacy protections in contracts and acquisitions language to ensure vendor compliance with security requirements; and provided recommendations for new language related to incidents involving contractors and contractor-operated systems to the DHS Privacy Office for inclusion in an update to the Department’s Privacy Incident Handling Guidance.

“The publication of this report underscores CBP’s commitment to promote transparency and accountability across the agency while ensuring that traveler data is well protected within our systems” said Matthew S. Davies, Executive Director of Admissibility and Passenger Programs in the Office of Field Operations at U.S. Customs and Border Protection.

The final report outlines the PDO’s findings and recommendations by determining whether the BE-E Program collects, maintains, uses, and shares information using TVS in a manner that is consistent and compliant with the privacy mitigations described in its PIA, the DHS Privacy Policy Guidance Memorandum on the Fair Information Practice Principles (FIPPs), and the CBP Directive for Privacy Policy, Compliance, and Implementation.

In conducting the assessment, CBP Privacy Office personnel reviewed existing privacy compliance documentation, policies, and legal requirements associated with TVS. They also developed a comprehensive questionnaire designed to aid in understanding the functions of TVS and clarify questions that arose during CBP Privacy Office’s review of program-related compliance documents.

To date, CBP has processed over 200 million travelers using biometric facial comparison technology and prevented more than 1,600 impostors from entry to the U.S.

Read the full report at CBP

Kylie Bielby
Kylie Bielby has more than 20 years' experience in reporting and editing a wide range of security topics, covering geopolitical and policy analysis to international and country-specific trends and events. Before joining GTSC's Homeland Security Today staff, she was an editor and contributor for Jane's, and a columnist and managing editor for security and counter-terror publications.

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