New EPIC Report Highlights DHS’s Extensive Collection and Circulation of Location Data

In a new report titled DHS’s Data Reservoir, EPIC Fellow Dana Khabbaz analyzes the ways that the Department of Homeland Security (DHS) collects and circulates location data. DHS’s collection of location data results in disproportionate and harmful surveillance of immigrant communities. As the report explains, DHS obtains precise location data from cell-phone apps, license plate readers, and social media as well as collecting common addresses people frequent like a home or work address from utility bills, credit reports, and state DMVs. 

The report focuses on Customs and Border Protection and Immigration and Customs Enforcement in its analysis of 5 sources of location information and 10 DHS systems—providing a more complete view of the location information available to DHS and the many DHS systems the location data ends up.

The report makes several policy recommendations that would move DHS more in line with national and international standards of privacy and limit unnecessary surveillance of immigrants:

• End purchases from or subscriptions to commercial data brokers and require a warrant before accessing sensitive location data;

• Minimize bulk collection and transfers of location data, and end use of sensitive location data for development of new leads;

• Limit storage of sensitive data;

• Disclose commercial databases that it accesses but does not store internally; and

• Define precise location information as personally identifiable information and comply with the Privacy Impact Assessment requirement of the E-Government Act of 2002.