Privacy Compliance Review of the ICE Pattern Analysis and Information Collection Law Enforcement Intelligence Sharing Service

The U.S. Government Accountability Office (GAO) recently conducted a review of the selected DHS systems that support counterterrorism including the U.S. Immigration and Customs Enforcement Pattern Analysis and Information Collection System (ICEPIC) Law Enforcement Sharing (LEIS) Service. GAO’s review found that the LEIS Service was not described in the Privacy Impact Assessment (PIA) that was approved for the ICEPIC system in January 2008. Given E-Government Act and DHS policy requirements for conducting PIAs, GAO recommended that the Chief Privacy Officer investigate whether the LEIS component of ICEPIC should be deactivated until a PIA that includes this component was approved. DHS concurred with the recommendation and as a result of the report findings and recommendations, the DHS Privacy Office initiated this Privacy Compliance Review (PCR).

ICEPIC is a toolset that assists the U.S. Immigration and Customs Enforcement (ICE) law enforcement agents and analysts in identifying suspect identities and discovering possible non-obvious relationships among individuals and organizations that are indicative of violations of the customs and immigration laws as well as possible terrorist threats and plots. The LEIS Service allows external law enforcement officers (federal, state, local, tribal and international partners) direct access to certain DHS law enforcement data sources compiled by ICEPIC. The objectives of our review were to 1) identify the cause of the privacy compliance gap regarding the LEIS Service and 2) evaluate whether the compliance gap warranted a deactivation of the LEIS Service until the PIA could be approved.  December 15, 2011