EPIC, Coalition Condemn SSA’s Linking of Social Security Data to DHS’s Illegal National Citizenship Database, Demand Immediate Reversal of Changes 

EPIC, joined by a coalition of 13 organizations, submitted comments today to the Social Security Administration (SSA) condemning its unlawful transfer of personal information to the Department of Homeland Security (DHS) for citizenship and immigration verification. SSA released an after-the-fact Systems of Records Notice that proposes a “new” routine use to disclose sensitive personal information to DHS despite the agency quietly sharing citizen data to DHS since May 2025.  

Over the past eight months, DHS and the U.S. Citizenship and Immigration Services (USCIS) have radically changed the Systematic Alien Verification for Entitlements (SAVE) System to pool individuals’ sensitive data across agencies—including SSA data. Originally used to facilitate the provision of public benefits, DHS has overhauled the SAVE system to serve as a national citizenship database and encouraged state and local SAVE users to use the system to purge their voter rolls. As EPIC made clear in comments to DHS, the changes to SAVE have been undertaken illegally.     

Despite an obligation to do so, SSA did not officially inform or seek feedback from the public about disclosing SSA data to DHS for citizenship verification through SAVE. Only now—after a lawsuit brought on behalf of EPIC, League of Women Voters, and several individuals by CREW, Federal Elections Center, and Democracy Forward—has SSA come before the public to seek retroactive authority.  

In the comments, EPIC and its partners explain that federal laws like the Privacy Act of 1974 do not allow SSA to disclose Social Security data through the SAVE system for purposes of citizenship verification and that the agency should have known better. In fact, SSA has historically warned that SSA data is not reliable for the purposes of confirming U.S. citizenship or immigration status because SSA records are not regularly updated by the agency. EPIC demands that SSA withdraw its notice, suspend the disclosure of sensitive SSA data to DHS for citizenship and immigration purposes, and ensure that users of the SAVE system delete all personal records and derived data wrongfully disclosed to them.  

Federal agencies cannot keep skirting its accountability and transparency obligations by acting illegally first and asking forgiveness later. This is the latest in a recent series of illegal, privacy-invasive actions by the federal government. EPIC is fighting them every step of the way.