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Take Action: Stop Voter Suppression!

  • Writer: Carl Blair
    Carl Blair
  • 21 hours ago
  • 4 min read

Deadline

Submit by Sunday, December 1, 2025, 10:59 p.m. CT. The notice requests comments “on or before December 1, 2025.”


What is this?

USCIS has issued a modified System of Records Notice (SORN) for the DHS/USCIS-004 Systematic Alien Verification for Entitlements (SAVE) Program


A SORN describes how an agency has changed its collection, usage, and sharing of people’s personal information. SAVE is a federal database run by the Department of Homeland Security (DHS) that all levels of government agencies use to verify the citizenship of people applying for benefits or licenses. USCIS’ SORN details how the federal government is expanding and changing SAVE’s purpose and data sharing agreements, including by using it to verify eligibility to vote. 

Why it matters?

Independent research shows SAVE data can be incomplete or outdated, which means using it for voter verification risks wrongly flagging eligible voters. SAVE’s design and record quality can lead to harmful mismatches that disenfranchise voters and burden election officials.

Context

DHS already tried to make these changes without telling the public. DHS did not publish this SORN or seek public comments until after a lawsuit was filed seeking records about data-sharing agreements with multiple states, including Texas. 

How to Submit Your Comment

  1. Open the official comment page and follow the instructions.

    1. Start here: regulations.gov comment form for Docket No. USCIS-2025-0337

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  1. Personalize your comment. Unique stories and concrete examples carry more weight than form letters.

  2. Do not include sensitive personal data you would not want posted publicly. The Federal Register notes that submissions are posted “without change,” including personal information.


Short Sample Comment (copy and personalize)

I am writing to comment on Docket No. USCIS-2025-0337 regarding the SAVE Program SORN…

General Concerns

The changes that have been made to SAVE are creating a vast and unguarded reservoir of Americans’ personal data, while failing to address major concerns over both the accuracy of that information and how that information will be protected. Given the longstanding concerns about the reliability of SAVE, this is not a risk worth taking.

The Secrecy around changes to SAVE

It is extremely troubling that DHS and USCIS did not notify the public and ask for comments about the changes they made to SAVE until after a lawsuit was filed.  These types of actions should never be hidden from public scrutiny because we deserve to know what our government is doing with our personal information.

Privacy Concerns

These changes to SAVE mean that for the first time in its history, the citizenship of every single person with a Social Security number can be checked by SAVE whether or not there’s any legitimate question about an individual’s citizenship status.  This is a massive and intrusive expansion of the government’s use and collection of our personal information that puts both our voting rights and our privacy rights at risk without any guardrails to protect them.

Accuracy

Many of the sources of information that SAVE draws from, including the Social Security Administration’s database, have proven to be unreliable in the past, so using them as a major part of the basis for removing someone from the voter rolls will end up disenfranchising eligible voters across the country.

Problems with Voter Roll Verification Programs (Texas Specific)

Texas has seen first hand how wrong things can go when attempts to verify voters’ citizenship status are based on debunked claims of noncitizen voting and use faulty information.  In 2019, at least 25,000 eligible Texans were flagged as non-citizens when our Secretary of State tried to purge our voter rolls.  The situation was such a fiasco that it ended up in multiple lawsuits, a settlement requiring the Secretary of State to stop the purge and update rolls with more up-to-date information, and the Secretary of State eventually resigning from office.  The nation should learn from our previous experience and not make this same type of mistake again.

Be sure to cite sources of information included in your comment.


Optional Personalization Prompts

  • If you are an election official or poll worker, describe how database mismatches slow or complicate your work.

  • If you are a naturalized citizen or part of a mixed-status household, describe concerns about data errors and how difficult it is to correct records.

  • If you work in privacy or cybersecurity, explain why expanded identifiers and new sharing increase risk.

  • If you are a civil rights advocate or community organizer, connect this to the importance of equal access to the ballot.


FAQs

Is this a proposed rule?

No, this is a System of Records Notice under the Privacy Act. It governs how DHS/USCIS uses and shares records in SAVE, including its stated purposes and routine uses. Federal Register

What changed in this SORN?

DHS says the SORN expands the SAVE purpose to include voter verification, adds U.S. citizens by birth to covered individuals, adds data elements such as full or truncated SSNs and driver’s license numbers, and updates record sources and routine uses.

Where do I find the official notice?

The Federal Register notice for Docket No. USCIS-2025-0337 is here, with the comment deadline and details on data elements and uses. Federal Register

Where can I learn more about SAVE’s risks to voters

See the Brennan Center’s explainer on how SAVE can produce mismatches that jeopardize eligible voters. Brennan Center for Justice


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