Take Action: Submit a Public Comment on SSA’s SAVE SORN

Deadline

Submit by Sunday, December 12, 2025, 10:59 p.m. CT. The notice requests comments “on or before December 12, 2025.”

What is this?

The Social Security Administration (SSA) has issued a modified System of Records Notice (SORN) detailing modifications to the use and sharing of information found in the records of the Master Files of Social Security Number (SSN) Holders and SSN Applications (60-0058). 

A SORN describes how an agency plans to collect, use, and share people’s personal information. The SSA’s SORN details how the federal government is expanding data sharing agreements between agencies, including by using Social Security numbers (SSN) to verify eligibility to vote via the Systematic Alien Verification for Entitlements Program (SAVE). 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.  Earlier this year, DHS and the SSA entered into an agreement where every SSN can be run through SAVE to verify the eligibility of every registered voter or applicant in the country.

Why it matters?

Independent research shows that SAVE data can be incomplete or outdated, which means using it for voter verification risks wrongly flagging eligible voters.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

Context

In violation of the Privacy Act of 1974, the SSA already made these changes without notifying the public or seeking public comments. In fact, this SORN was not published until after a lawsuit was filed seeking records about data-sharing agreements with multiple states, including Texas.

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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. SSA-2025-0225

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

3. 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.

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Key Points You Can Make

Accuracy and Harm

The Social Security Administration has never collected information for the purpose of checking the citizenship of the approximately 174 million voters registered in the United States, and the millions of people who register to vote each year. In addition, SAVE itself was not built for determining voter eligibility, and its records, including those from the SSA, may be incomplete or outdated. Using this type of information to check the citizenship of entire voter lists risks false mismatches that disenfranchise eligible citizens.

Scope Creep and Privacy

The Social Security Administration’s participation in SAVE means that for the first time ever, the citizenship of every single person with a Social Security number can be checked via 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 meaningful guardrails to protect them.

Transparency and Public Process

The SSA should fully and publicly disclose all of its data-sharing arrangements with DHS regarding its participation in SAVE, publish clear accuracy metrics and error-correction rates, and provide robust legal redress for people flagged in error. Litigation seeking these records underscores the need for transparency.

Election Administration Burden

Over-reliance on a database not designed for voter eligibility increases workload and confusion for local officials and can slow list maintenance and registration processes. The Brennan Center details these risks: Brennan Center for Justice

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Short Sample Comment (copy and personalize)

I am writing to comment on Docket No. SSA-2025-0225 regarding changes to the use of information from the Master Files of Social Security Number (SSN) Holders and SSN Applications (60-0058) .

Issue 1: General Concerns

Both the changes that have been made to SAVE, and the Social Security Administration’s participation in 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.

Issue 2: The Secrecy around changes to SAVE

It is extremely troubling that the Social Security Administration did not notify the public or ask for public comments about their participation in 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.

Issue 3: Privacy Concerns

The Social Security Administration’s participation in SAVE means that for the first time ever, the citizenship of every single person with a Social Security number can be checked via 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 meaningful guardrails to protect them.

Issue 4: Accuracy

Many of the sources of information that SAVE draws from, including the Social Security Administration’s own 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.

Issue 5: 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.

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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 required under the Privacy Act of 1974. It governs how the Social Security Administration uses and shares data with DHS and USCIS for use in SAVE, including its stated purposes and routine uses: Federal Register

What changed in this SORN?

This SORN details the Social Security Administration’s sharing of information with DHS and USCIS. The SSA’s participation in SAVE means that for the first time ever, the citizenship of every single person with a Social Security number can be checked via SAVE whether or not any legitimate question about their citizenship exists.

Where do I find the official notice?

The Federal Register notice for Docket No. SSA-2025-0225 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

Click Here To Submit A Public Comment