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Monday, February 6, 2023

USCIS Oversight of Digital Requests for Info in ‘Alien Files’ Assessed in Privacy Report

The US Citizenship and Immigration Services (USCIS) has developed the Electronic Workload Reporting and Tracking System (EWRTS) to accurately record and track actions taken to respond to Alien File (A-File) requests made at the National Records Center (NRC) — the custodian of inactive Alien Files.

According to DHS’s Privacy Impact Assessment (PIA) of the system, USCIS, Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE) all use A-Files in the course of performing their mission and may request A-File content from USCIS NRC at any time.

Information in EWRTS includes contact information of DHS personnel requesting information and the Alien Registration Number (A-Number) for subjects of inquiry. USCIS conducted the PIA to comprehensively discuss the privacy risks and mitigations associated with the use of an electronic database to record and track incoming information requests.

The PIA said that, “To support immigration benefit operations, USCIS assembles a paper-based file, known as the A-File, which contains official immigration records of persons who are not citizens or nationals of the United States, a function previously the responsibility of the old Immigration and Naturalization Service (INS), which began issuing each alien an Alien Registration Number in 1940, and on April 1, 1944, started using this number to create individual A-Files.

“A-Files contain all records of any case of an individual not yet naturalized including records created as he or she passes through the US immigration and inspection process, the citizenship process, and, when applicable, records related to any law enforcement action against or involving the alien,” the PIA stated.

Although, USCIS is the custodian of the A-File, USCIS, which performs the immigration benefit adjudication process; CBP, which performs the border enforcement and inspection processes; and ICE all create and use A-Files in the course of performing their mission requirements, which includes the immigration benefit adjudication process; border enforcement and inspection processes; and investigatory, deportation and immigration court functions.

“Most inactive and less active paper A-Files are currently under the control of the USCIS National Records Center and the National Archives and Records Administration’s (NARA) Kansas City Federal Record Center (KCFRC). NRC is responsible for the maintenance of over 25.1 million inactive A-Files, and for providing its customers with timely access to information contained in the A-Files. USCIS, CBP, and ICE employees, who are stationed both domestically and internationally, require access to A-Files regularly to assist in adjudicating benefits, investigating immigration violations and enforcing border protections,” the PIA explained.

The PIA further explained that, “The USCIS NRC Information Management and Field Services Branch (IMFS) Information Liaison (IL) Section serves as the central point of contact for A-File information requests from USCIS, CBP and ICE.

The mission of IL is to provide complete, accurate and timely information from A-Files housed at the NRC to authorized requesters within specified timeframes; to make updates to electronic records; and to correct paper files housed at NRC.

IL provides 24/7 access to information from A-Files located at the NRC and the KCFRC to DHS requestors from USCIS, CBP and ICE all over the world.

The PIA stated that, “IL developed EWRTS as a stand alone application “only accessible at the NRC, to record and track the processing and response of A-File information requests from USCIS, CBP and ICE. IL also uses EWRTS to generate production reports to measure, analyze, and track time spent on processing information requests by IL employee and unit performance through statistical queries and record reviews. These reports may contain the IL employee’s User ID, in addition to production data.”

Reports are shared with NRC and USCIS leadership, and USCIS, CBP and ICE officers may request content from an individual’s A-File from the IL to receive the most up-to-date information about an individual.

USCIS, CBP and ICE officers may also request copies of information within an individual’s A-File, including copies of documents, photographs or fingerprints. USCIS, CBP and ICE use this information to confirm the identity of a subject or verify a subject’s status or class of admission. Officers may also request that IL update or correct the Central Index System (CIS) with name, aliases, date of birth, classification of admission, citizenship data, parents’ names, FBI number, Social Security Number, passport number and entry to or removal from the United States history data.”

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The Government Technology & Services Coalition's Homeland Security Today (HSToday) is the premier news and information resource for the homeland security community, dedicated to elevating the discussions and insights that can support a safe and secure nation. A non-profit magazine and media platform, HSToday provides readers with the whole story, placing facts and comments in context to inform debate and drive realistic solutions to some of the nation’s most vexing security challenges.

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