The World Privacy Forum sent a detailed letter (PDF, 18 pages) September 18, 2018 to the Secretary of Homeland security outlining our substantive concerns regarding the US Department of Homeland Security (DHS) Customs and Border Protection (CBP) and Transportation Security Administration (TSA) biometricentry and exit program. The World Privacy Forumletter calls on the Secretary to provide formal notice and solicit public comments pursuant to the Administrative Procedure Act, and to address and resolve the additional regulatory, legal and policy issues discussed in the letter.
Although DHS issued three Privacy Impact Assessments regarding this program, DHS failed to provide formal notice and solicit public comments pursuant to requirements of the Administrative Procedure Act (APA) for its Phase I and Phase II pilot tests of the biometric entry and exit system. DHS failed to do so despite an extensive implementation of the stage II pilot of biometric technology at many airports with international flights, affecting millions of travelers annually.
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