EPIC Comments Call on USDA to Abandon Plan for Nationwide SNAP Database

Yesterday, EPIC submitted comments to the U.S. Departments of Agriculture urging USDA to retract its deficient System of Records Notice (SORN) and to stop its unlawful collection of the personal data of millions of SNAP recipients.

USDA previously suspended its data demand in response to a lawsuit filed by Student Defense, Protect Democracy, the National Center for Law and Economic Justice, and EPIC that challenged USDA’s data demand for failing to publish any applicable SORNs mandated by by the Privacy Act, documentation mandated by the Paperwork Reduction Act, and Privacy Impact Assessments (PIAs) mandated by section 208 of the E-Government Act. USDA now seeks to resume its data demand by establishing a system of records that would store the sensitive personal data of every SNAP recipient and applicant in the country.

In its comments, EPIC explained that the SORN is fatally deficient and exhibits significant errors and omissions. EPIC urged the USDA to withdraw its SORN as it (1) lacks basic information like proposed record disposal policy, thereby exposing SNAP recipients and applicants to heightened risk of data breaches and misuse; (2) proposes “routine uses” for SNAP data which are not compatible for the purposes for which SNAP data was collected and far exceed limits on data use set by Congress; and (3) fails to show that USDA’s data demand is necessary to accomplish any of its lawful obligations as required by the Privacy Act.

EPIC routinely monitors, analyzes, and educates the public about the collection, use, retention, and transfer of personal information by federal agencies, including large-scale databases and mass surveillance programs. EPIC has also undertaken significant research, advocacy, and public education concerning the systems and databases used in the provision of public benefits, including SNAP.