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Comments to NARA re Customs and Border Patrol (CBP) Document Destruction Proposal

Earlier this week, we posted to let readers know about the Customs and Border Patrol (CBP) draft records schedule submitted to NARA that would destroy important civil rights records. CBP was asking for 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” (NARA RFC Control Number DAA-0568-2018-0001).

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 is at the end of the proposed CBP records schedule (p11-14)). The ACLU has more background and context on these important records.

A group of organizations working on immigration issues, government accountability, civil liberties, refugee and immigration history, libraries, and more (including PEGI Project and FGI!) have signed on to a 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 letter is extremely thorough and deeply researched and shows how researchers use NARA’s records, puts agencies’ FOIA support (or lack thereof) in historical relief, and offers a strong argument for why these records in particular from the CBP should be designated as permanent.

I encourage our readers to read the letter. Records retention of federal agency records is extremely important to a wide swath of professional, library, and civil society organizations. And this is a great example for how to write a comment to a federal agency.

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