The American Immigration Council and the American Immigration Lawyers Association (AILA) summited comments to a Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) information collection request on the collection of information from certain undocumented individuals who present themselves at land borders.
The comments urge the administration to continue thinking through solutions that reduce processing time while not externalizing critical government functions like border processing or using unreliable technologies like facial recognition. The organizations state that they support CBP’s desire to reduce processing times for individuals who present themselves at land borders, but do not support the proposed request due to its lack of clarity and meaningful justification raise significant concerns for the nearly 100,000 individuals who CBP estimates will be impacted by the new process.
The comments detail the following specific concerns: lack of training/information about training, purported voluntariness of submission, externalization of border processing, lack of proof regarding the stated reduction in processing times, concerns regarding efficacy, privacy, and secondary usage, and lack of clarity regarding data retention and use by CBP.
