response to CBP proposed social media identity collection

gistfile1.txt

Re: Proposed Changes to CBP Forms I-94, I-94W
https://www.federalregister.gov/articles/2016/06/23/2016-14848/agency-information-collection-activities-arrival-and-departure-record-forms-i-94-and-i-94w-and

Title: Arrival and Departure Record, Nonimmigrant Visa Waiver Arrival/Departure, and Electronic System for Travel Authorization (ESTA).
OMB Number: 1651-0111.
Form Numbers: I-94 and I-94W.


The proposed rule changes are ill-advised and should not be implemented, for several reasons:

1) those actually intending harm or malice (or who are simply uncomfortable with what's being requested) can simply opt not to provide the requested information, or can provide fictitious or incomplete information - as long as this is optional, it is pointless as a vetting method;
2) there's no way to make this requirement mandatory, as many applicants will not have any social media accounts to provide (or will have accounts with one of hundreds of varying providers with varying degrees of access or records retention, located in jurisdictions around the globe);
3) there's no way to confirm authenticity or completeness of the provided information (if any) - entirely legitimate (or fictitious) accounts could be submitted that do not represent the totality of a person's online identity.

Given that it is completely impossible to assure the quality, accuracy or comprehensiveness of the proposed data to be collected, attempting to do so is a waste of time and money that contributes no useful information to the vetting process. Indeed, the proposed changes merely further cloud the vetting process with inconsistent and entirely arbitrary information that cannot (by definition) be relied upon for any value at all.

In conclusion: adding to the hay to the stack does not improve one's chances of finding the needles.

sincerely,
Scott Francis