First Focus on Children submitted the following comment to the Department of Homeland Security because we are deeply concerned about the many ways this proposed rule (USCIS Docket No. USCIS-2019-0007, RIN 1615-AC14) will unnecessarily require children to provide a broad scope of information, likely leading to continuous surveillance of them and their families and harm to their safety and well-being.


Immigrant children and families already face many barriers to lawful status in the United States. Many are seeking protection from persecution and violence they experienced either here in the United States or in their home country. Others are seeking to reunify with relatives. All must navigate an already complex and confusing immigration system. Without policies that take their particular needs into account, children and families face wrongful denials of their applications, separation, and struggles to build a new life in the United States. The proposed rule unquestionably does not consider the particular needs of children and families. It would force children and families to submit to highly intrusive and overly broad submissions of their personal information without justification, violating their rights to privacy and exposing them to harm.

Read the full comment.