SAVE Self Assessment Guide
Self-Assessment GuideFor SAVE Program Web and Web Services-based UsersJuly 2012M-1063
0Table of ContentsI. INTRODUCTION . 1PURPOSE OF THIS DOCUMENT . 1BACKGROUND. 1COMPLIANCE ELEMENTS . 1SELF-ASSESSMENT GUIDE BENEFITS . 1II.HOW TO USE THE SELF-ASSESSMENT GUIDE. 2III. SELF-ASSESSMENT CHECKLIST STANDARDS . 3PART 1: TRAINING. 3PART 2: VERIFICATION PROCEDURES . 5PART 3: SECURITY AND PRIVACY. 7PART 4: APPLICANT ASSISTANCE . 11PART 5: NOTIFICATIONS TO SAVE . 13PART 6: LEGAL RESTRICTIONS AND COMPLIANCE. 15IV. REFERENCED AND SUPPORTING DOCUMENTATION . 16V. GLOSSARY . 17COMMONLY USED ACRONYMS AND TERMS. 17Self-Assessment Guide for SAVE Program Web and Web Service Users
1I. INTRODUCTIONPURPOSE OF THIS DOCUMENTThe Systematic Alien Verification for Entitlements (SAVE) Program developed this SAVESelf-Assessment Guide as a tool for agencies to perform internal monitoring and complianceassessments to support proper use of SAVE and improve the overall integrity of their SAVEverifications.The Memorandum of Agreement (MOA) between your agency and the Department ofHomeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), SAVEProgram, establishes the terms and conditions for your agency’s use of SAVE. TheVerification Division Monitoring and Compliance (M&C) Branch monitors the use of SAVE toensure its proper use. Agencies using SAVE are encouraged to establish their own internalmonitoring and compliance program.BACKGROUNDAgencies using SAVE are responsible for ensuring that all SAVE users follow all SAVErequirements. The MOA specifies that your agency must ensure that everyone performingverification procedures is complying with all requirements in the SAVE MOA, SAVE ProgramGuide (Program Guide), and web-based tutorial and updates to these requirements. (SeeSection II B.(1)(f) of the MOA).COMPLIANCE ELEMENTSThe SAVE Program has identified general requirements that agencies should follow whenusing SAVE. Although the general requirements for the use of SAVE are established by anagency’s MOA, the questions and standards in this guide are framed to help the agencyidentify and address noncompliant activities. For the most part, noncompliant activities aregeneral misuse of SAVE, but in some instances could be more serious in nature.Because there are instances when an agency’s particular needs regarding the use of SAVErequire a revision of certain provisions of the agency’s MOA, an individual agency’s MOAmay not follow the standard MOA format. Therefore, you must look at your agency’s MOA todetermine whether any aspects of this guide may have to be altered to suit your agency’scircumstances.SELF-ASSESSMENT GUIDE BENEFITSImplementation of a voluntary self-assessment program helps agencies to: Detect misuse and noncompliant activities concerning SAVE Resolve noncompliant activities quickly and effectively Promote proper use and prevent noncompliance Detect and resolve redundant administrative processes Improve compliance with SAVE policies and procedures Increase assurance that only eligible applicants receive benefitsSelf-Assessment Guide for SAVE Program Web and Web Service Users
2II. HOW TO USE THE SELF-ASSESSMENT GUIDEThis Self-Assessment Guide has six parts; each part addresses a topical area suggested foryour internal monitoring and compliance program. Each part includes a checklist to guideyour review of the activities related to the topical area. The checklists are for your agency’sinternal use; you are not required to send the compliance checklist to SAVE. Part 1: Training Part 2: Verification Procedures Part 3: Security and Privacy Part 4: Applicant Assistance Part 5: Notifications to SAVE Part 6: Legal Restrictions and ComplianceSelf-Assessment Guide for SAVE Program Web and Web Service Users
3III. SELF-ASSESSMENT CHECKLIST STANDARDSPART 1: TRAININGAll SAVE users must be properly trained before using SAVE. This will help ensure thatbenefit applicants are not inappropriately denied or awarded benefits. The MOA and theProgram Guide require everyone performing verification procedures to complete requiredSAVE training before using SAVE. (See Section IV.B.(1)(d) of the MOA and Section 4 of theProgram Guide). This training includes:1) reading the SAVE Program Guide,2) taking the latest version of SAVE Training tutorial(s) and3) Refreshing knowledge of these requirements each time they are updated.Also refer to the Program Guide at Section 5.1.Note: The MOA incorporates by reference any requirements in the Program Guide and webbased tutorials. To ensure compliance, your agency must monitor SAVE notifications to beaware when SAVE updates requirements and training tutorials and ensure that SAVE usersare aware of these updates. SAVE may make these notices in the form of ticker messageson the SAVE access method, by email, letter, or via the SAVE website (www.uscis.gov/save).#Question1.1Has everyone performingverification procedures read thelatest version of the SAVEProgram Guide, before usingSAVE?1.21.31.4Has everyone performingverification procedures takenthe latest version of Webtutorial(s) before using SAVE?Is your agency monitoring theSAVE notices and ensuring thateveryone using SAVE is awareof all updates?Does everyone performingverification procedures have aworking knowledge ofrequirements contained in thelatest version of the SAVEProgram Guide?1.5Does everyone performingverification procedures have aworking knowledge ofrequirements contained in thetutorial(s), as updated?1.6Does everyone performingverification procedures have aworking knowledge ofrequirements contained in theMOA, as updated?Response Selection Yes No Other Yes No Other Yes No Other Yes No Other Yes No Other Yes No OtherSelf-Assessment Guide for SAVE Program Web and Web Service UsersResponse Notes
4#1.7QuestionIs your agency ensuring thateveryone using SAVE iscomplying with all requirementsin questions 1.4, 1.5 and 1.6, asupdated?Response Selection Yes No OtherSelf-Assessment Guide for SAVE Program Web and Web Service UsersResponse Notes
5PART 2: VERIFICATION PROCEDURESSAVE verification process requirements must be followed to ensure the integrity of theverification process. If SAVE verification process requirements are not followed, applicantscould be inappropriately denied or awarded benefits.The MOA requires that all SAVE users establish the identity of the benefit applicants andrequire the applicants to present immigration or naturalization documentation that containsthe applicants’ information (e.g., alien registration number, passport number or I-94 number)before beginning a request for verification. (See Section IV.B.(1)(a) of the MOA and Section3.1of the Program Guide).Additionally, the MOA requires users to physically examine the documents presented by thebenefit applicant and determine whether the document(s) reasonably appear(s) to begenuine and relate to the individual. (See Section IV.B.(1)(b) of the MOA and Section 3.5.2 ofthe Program Guide).SAVE has a three step process. Depending on the circumstances, you may need to use one,two, or all three steps to make certain that all available records have been searched to verifyan applicant. These steps are1.Electronic initial verification 2. Electronic second step verification 3. Manual third step verification.Unless these additional verification steps are followed as required by SAVE, the verificationprocess may be incomplete and the integrity of the process compromised. Accordingly, theMOA and the Program Guide require users to perform all required additional verificationprocedures that the benefit applicant requests after initiating electronic verification. Thisadditional verification includes second step electronic verifications and third step submissionof copies of the benefit applicants’ immigration documents to SAVE. (See Section IV.B.(1)(h)of the MOA and Section 3.3 and 5.1 of the Program Guide).Sometimes it is necessary to go straight to the third step, manual verification. The ProgramGuide requires users to skip automated initial verification and second step verification andinstead submit a Form G-845 when a benefit applicant presents: A document that appears to be counterfeit or altered, which can be indicated by a photosubstitution or discolored inkAn unfamiliar DHS documentA document that indicates immigration status, but does not contain an A-NumberA foreign passport and/or Form I-94 with an “Admission for Permanent Residence”endorsement more than one year old(See Section 3.5.2 of the Program Guide)Occasionally a SAVE response does not match the information on the benefit applicant’simmigration document. The Program Guide requires users to initiate additional verificationwithout being prompted to by SAVE when there is a material discrepancy betweeninformation on a benefit applicant’s immigration document and the SAVE response. (SeeSection 3.3 of the Program Guide).Self-Assessment Guide for SAVE Program Web and Web Service Users
6ResponseSelectionQuestion2.1 Yes No OtherDoes everyone require the benefit applicantto present his/her immigration ornaturalization document that contains theinformation (e.g., alien registration number,passport number or I-94 number, etc.)required by the SAVE Program? Yes No OtherDoes everyone physically examine thedocument presented by the benefit applicantto determine whether the documentreasonably appears to be genuine and relateto the benefit applicant? Yes No Other Yes No Other Yes No Other Yes No OtherIs the identity of the benefit applicantestablished before running a SAVE query onthe applicant?2.22.32.42.5After beginning electronic verificationrequests, are all users performing alladditional verification procedures the SAVEProgram requires and/or the applicantsrequest, including second step electronicverifications and third step submission ofcopies of the benefit applicants’ immigrationdocuments to SAVE?Are all users skipping automated initialverification and second step verification andsubmitting a Form G-845 when a benefitapplicant presents:a) a document that appears to be counterfeitor altered,b) an unfamiliar DHS document,c) a document that indicates immigrationstatus, but does not contain an A or I-94Number,d) a foreign passport and/or Form I-94 withan “Admission for Permanent Residence”endorsement more than one year old?2.6Is everyone initiating additional verificationwhen there is a material discrepancybetween information on the benefitapplicant’s immigration documents and theSAVE response?Self-Assessment Guide for SAVE Program Web and Web Service UsersResponse Notes
7PART 3: SECURITY AND PRIVACYThis section addresses actions your agency must take to ensure that information provided bySAVE is properly protected from unauthorized disclosure.To prevent access to SAVE by unauthorized individuals, the MOA requires that SAVE usersare provided with and maintain User IDs only while they have a need to perform verificationprocedures. (See Section IV.B.(1)(e)). Accordingly, an individual’s User ID should beterminated immediately when they no longer need to perform verifications. Also refer to theGuide at Section 5.2.The MOA directs your agency to follow the requirements of the Federal Information SecurityManagement Act (FISMA) and Office of Management and Budget (OMB) guidance asapplicable to electronic storage, transport of records between agencies, and the internalprocessing of records received by the agency under the terms of the MOA. (See SectionIV.B.(1)(j)).FISMA generally speaks to the legal obligations of the federal government. As reflected inthe MOA, state and local governments eligible for participation in SAVE must agree to ensurethe integrity of DHS data through compliance with federal privacy laws.To be FISMA compliant, state and local agencies should refer to the Department ofCommerce, National Institute of Standards and Technology (NIST) guidelines. Your agencyis responsible for implementing the NIST guidance in a manner best suited to its availableresources and needs. According to the NIST guidance, agencies should: Conduct periodic assessments of risk, including the magnitude of harm that could resultfrom the unauthorized access, use, disclosure, disruption, modification or destruction ofinformation and information systems that support the operations and assets of theorganization.Develop policies and procedures that are based on risk assessments, cost-effectivelyreduce information security risks to an acceptable level and ensure that informationsecurity is addressed throughout the lifecycle of each organizational information system.Have subordinate plans for providing adequate information security for networks,facilities, information systems or groups of information systems, as appropriate.Conduct security awareness training to inform personnel (including contractors and otherusers of information systems that support the operations and assets of the organization)of the information security risks associated with their activities and their responsibilitiesin complying with organizational policies and procedures designed to reduce these risks.Conduct periodic testing and evaluation of the effectiveness of information securitypolicies, procedures, practices and security controls to be performed with a frequencydepending on risk, but no less than annually.Develop a process for planning, implementing, evaluating and documenting remedialactions to address any deficiencies in the information security policies, procedures andpractices of the organization.Develop procedures for detecting, reporting and responding to security incidents.Develop plans and procedures to ensure continuity of operations for information systemsthat support the operations and assets of the organization.The MOA also requires your agency to follow the Privacy Act and other applicable laws,regulations and policies, including but not limited to all OMB and DHS privacy guidance, inconducting verifications and safeguarding, maintaining and disclosing any data providedSelf-Assessment Guide for SAVE Program Web and Web Service Users
8under the MOA. (See Section IV.B.(1)(l) of the MOA and 5 U.S.C. Section 552a of thePrivacy Act).The Privacy Act speaks to the legal obligations of the federal government. However, stateand local governments eligible for participation in SAVE must agree to ensure the integrity ofDHS data through compliance with federal privacy laws.The Privacy Act governs the means by which the U.S. government collects, maintains, usesand disseminates the personally identifiable information (PII) of U.S. citizens and lawfulpermanent residents (LPRs). However, under DHS policy, to the extent practicable, privacyprotections afforded to U.S. citizens and LPRs must also be afforded to visitors and alienswhen there is a mixed system containing information on U.S. persons and visitors and aliens.Refer to the Fact Sheet, “Information for SAVE Users: Your Responsibilities for Handling andProtecting Personal Information,” and Part 5: Notifications to SAVE below for additionalinformation on PII. Compliance with the FISMA elements described above and otherrequirements of the MOA will largely ensure that the privacy of an individual’s PII issafeguarded. Any documents containing PII obtained as part of or the result of a SAVEverification must receive the same level of protection as electronic SAVE information. Pleasenote that under Department of Homeland Security Management Directive, MD 11042.1,“Safeguarding Sensitive but Unclassified (For Official Use Only) Information,” (2005) youragency should mark documents containing PII with privacy language such as “For OfficialUse Only” to identify the need to protect the information from inappropriate disclosure. Alsorefer to the Fact Sheet, “Information for SAVE Users: Your Responsibilities for Handling andProtecting Personal Information,” for additional information.Safeguarding SAVE informationThe MOA requires your agency to safeguard SAVE information and access methods toensure that it is not used for any other purpose than described in the MOA. It also requiresyour agency to protect the information’s confidentiality, ensuring that it is not disclosed to anyunauthorized person(s) without the prior written consent of DHS-USCIS. (See SectionIV.B.(1)(k)).The MOA further requires that your agency ensures that information provided by DHS-USCISis used solely for determining the eligibility of persons applying for the benefit(s) specified inthe MOA. (See Section IV.B.(1)(i)).Additionally, the MOA specifies that any person who obtains SAVE information covered bythe Privacy Act under false pretenses or uses it for any purpose other than as provided forin the MOA may be subject to criminal penalties. (See section VI.(C)(2)).Under the Privacy Act your agency must: Notify individuals applying for benefits that the personal information that your agencyis collecting will be used to verify their immigration status through SAVE. Advise individuals applying for benefits that they do not have to provide theinformation. Advise individuals applying for benefits of the consequences of not providing theinformation.Also refer to the Fact Sheet, “Information for SAVE Users: Your Responsibilities for Handlingand Protecting Personal Information,” for additional information.Self-Assessment Guide for SAVE Program Web and Web Service Users
9Please Note: Benefit applicants seeking information about themselves should be directed tothe Freedom of Information and Privacy Act page of www.uscis.gov for directions onsubmitting a Privacy Act request to DHS-USCIS. For additional information regardingprohibitions on the use of SAVE, please also reference the Legal Restrictions andCompliance Section of this Checklist and the Program Guide at Section 5.2.#Question3.1Response Selection Yes No Other Yes No Other Yes No Other Yes No Other Yes No OtherIs your agency ensuring that itis not disclosing informationprovided by SAVE to anyunauthorized person(s) withoutthe prior written consent ofDHS-USCIS? Yes No OtherIs your agency safeguardingSAVE access methods andinformation provided by SAVEto ensure that it is not used forany other
Self-Assessment Guide for SAVE Program Web and Web Service Users II. HOW TO USE THE SELF-ASSESSMENT GUIDE This Self-Assessment Guide has six parts; each part addresses a topical area suggested for your internal monitoring and compliance program. Each part includes a checklist to guide y
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