The American Immigration Council, the Immigration Defense Clinic at Colorado Law, and the American Immigration Lawyers Association, submitted a comment in opposition to the Department of Homeland Security (DHS) proposed rule on the "Collection and Use of Biometrics by U.S. Citizenship and Immigration Services."

The regulation would drastically redefine "biometrics" in the immigration context and significantly expand the population of individuals subjected to collection by DHS. 

The comment explains how the changes are contrary to current law and describes the significant privacy implications of these proposed changes for citizens and non-citizens alike.