Report: CBP lacks 'clear authority' to collect SSNs for system access
U.S. Customs and Border Protection derives employee and contractor IT systems passwords from user Social Security numbers. But the agency may not have the authority to collect that personally identifiable information, according to a privacy report.
An IT system used by the Department of Homeland Security's Customs and Border Protection agency to collect Social Security numbers of employees and contractors is operating without "clear legal authority," according to an agency privacy assessment.
CBP uses the enterprise system, known as REMEDY, to manage IT help requests across the agency. The program collects SSNs to generate a "HashID" to give users' account access, but the audit calls into question the legality of that practice.
"This risk is not mitigated," auditors conclude. The only way to fully address the problem, they argue, is for CBP to develop a "centralized, enterprise-level identity management system," to replace the SSN-derived HashID.
There is also a risk that REMEDY over-collects information by requiring an SSN to identify a user, the assessment says. Auditors deemed that risk "partially mitigated." CBP deletes SSNs from the mainframe system when they are no longer needed to identify non-CBP persons, but this typically happens only after someone hasn't signed into their account for some time.
Use of the REMEDY system is not limited to officials from CBP and other agencies. The public interacts with the system when submitting information to the "contact us" portion of CBP's customer service webpage, for example. However, CBP does not collect the SSNs of people using the agency's help desk for assistance with travel programs, according to the report.
DHS also recently released a privacy assessment of a case management system used by U.S. Citizenship and Immigration Services to track responses to decisions on immigration benefits.
The legal regime undergirding the USCIS system is missing a key piece, according to auditors: the program does not yet have a records retention schedule approved by the National Archives and Records Administration.
"Without an approved retention schedule, there is a risk that information may be retained longer than necessary and may increase the potential of an unauthorized disclosure," the audit states. USCIS is working with NARA to develop a retention schedule.
The privacy assessments underscore the extent to which collection of personal information can vary by agency across DHS' vast bureaucracy. The scorecards also serve as a reminder that legal guidelines can be slow to catch up to data collection capabilities.