LDF Opposes Department of Homeland Security’s Proposed Modification of System of Records, Citing Risks of Inaccuracies and Privacy Violations

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Today, LDFissued a public comment strongly opposing the Department of Homeland Security's proposal to expand theSystematic Alien Verification for Entitlements Program (SAVE). In the letter, LDF notes that any future changes should be developed through a transparent, deliberative process that prioritizes data accuracy, civil rights protections, and the fundamental right to vote. The U.S. Department of Homeland Security's proposal to modify and reissue a system of records notice would transform the Systematic Alien Verification for Entitlements Program from a narrow benefit-verification tool into a broad identity-matching system that pulls data from multiple federal and state sources, creating heightened risks of inaccurate matches, privacy violations, and misuse in voter eligibility determinations. SAVE relies on incomplete, outdated, and inconsistent underlying data, and its use for voter eligibility verification will inevitably lead to erroneous results and wrongful voter removals. It encourages states to take actions that may wrongfully cancel the registrations of eligible voters and places Black voters and naturalized citizens at particular risk of disenfranchisement. LDF strongly urges DHS not to move forward with the proposed rule or continued expansion of SAVE. Instead, the department should suspend the expanded functionalities, conduct a comprehensive privacy and data integrity review, and fully comply with all notice and procedural requirements.

Read the full comment here.

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Founded in 1940, the Legal Defense Fund (LDF) is the nation's first civil rights law organization. LDF's Thurgood Marshall Institute is a multi-disciplinary and collaborative hub within LDF that launches targeted campaigns and undertakes innovative research to shape the civil rights narrative. In media attributions, please refer to us as the Legal Defense Fund or LDF. Please note that LDF has been completely separate from the National Association for the Advancement of Colored People (NAACP) since 1957-although LDF was originally founded by the NAACP and shares its commitment to equal rights.