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Please send comments to NARA re CBP’s draft records schedule seeking to destroy important civil rights records

[UPDATED 9/28/2020 5:30pm PST: I’ve taken down the link to the Google form. Please submit comments via REGULATIONS.GOV. Thanks! JRJ]

[UPDATED 9/29/2020: I deleted the link to the letter since it was a draft. When the final letter is published, I’ll be sure to post. JRJ]

**** DEADLINE for INDIVIDUAL PUBLIC COMMENTS is WEDNESDAY 30 September ****

The National Archives and Records Administration (NARA) has extended the commenting period to 30 September on a proposed records schedule regarding Department of Homeland Security (DHS), Customs and Border Protection (CBP) (Control Number DAA-0568-2018-0001), 85 FR 47248 (Proposed CBP Schedule).

CBP seeks NARA’s approval to destroy after four years “records developed to track and monitor complaints that are or will be investigated by DHS Civil Rights and Civil Liberties (CRCL) regarding alleged violations of civil rights and civil liberties” and associated “Requests for Information.”

CBP further proposed 25-year retention periods for “records pertaining to administrative and criminal investigations on [CBP] employees, contractors, and those in CBP custody,” as well as records and reports pertaining to Prison Rape Elimination Act (PREA) allegations. A July 9, 2020 NARA appraisal memorandum accompanying the Proposed CBP Schedule recommends approving it in full (Appraisal Memorandum).

FGI has signed on to a DRAFT letter to NARA raising deep concerns (PDF) regarding CBP’s proposed records schedule and requesting that NARA revise the schedule and permanently retain the records at issue. The comments were crafted by groups working on immigration issues, government accountability, civil liberties, refugee and immigration history, and more. The letter is extremely thorough and shows how researchers use NARA’s records and and offers a strong argument for why these in particular from the CBP should be designated as permanent.

If any of our readers would like to submit individual comments, please feel free to submit directly via regulations.gov (Control Number DAA-0568-2018-0001). You can also read others’ comments on regulations.gov.

**** DEADLINE for INDIVIDUAL PUBLIC COMMENTS is WEDNESDAY 30 September ****

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