Comment Submitted by Anonymous
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed expansion of the AR-11 form, arguing that it over-extends the form's purpose into a surveillance tool that collects unnecessary personally identifiable information. They express concerns regarding data security, the lack of a new Privacy Impact Assessment (PIA), and potential violations of privacy policies and the Paperwork Reduction Act.
I am writing in strong disapproval of the proposed changes to turn the routine AR-11 change-of-address form into a broader surveillance tool. The proposed information collection over-extends the intended purpose of these routine forms and creates incredible security risks for people. The government does not specify how this expansion of collected data will be protected or used. Many of the new questions would collect personally identifiable information, so USCIS must prevent the risk of data leaks, unauthorized access, and misuse. This process of securing personally identifiable information requires a Privacy Impact Assessment (E-Government Act, Section 208). However, no new PIA has been completed or announced, and the previous PIA from August 2018 only covered using cloud storage for AR-11 address data, NOT the gathering of educational, employment, and benefit data. Gathering these new categories of data will require a new PIA. An additional serious security concern is the potential use of AI in processing this data, and a process that prevents the risks of leaks or misuse of data is imperative. This proposed sloppy overextension of necessary data-collection violates DHS’s own privacy policy and the Fair Information Practice Principles (FIPP), which require agencies to limit data collection to what is necessary for the stated purpose. No legitimate reason has been put forth as to why these proposed changes are necessary, much less why standard PIA requirements and the Paperwork Reduction Act are being violated. For this reason I strongly urge USCIS to keep the AR-11 as a narrow address reporting form and withdraw the proposed revisions.