DHS ICE PIA 015b EID EARM 3.0

Privacy Impact Assessment Update
for the

Enforcement Integrated Database (EID)
ENFORCE Alien Removal Module (EARM 3.0)
DHS/ICE-PIA-015(b)
May 20, 2011
Contact Point
James Dinkins
Executive Associate Director
Homeland Security Investigations
U.S. Immigration and Customs Enforcement
(202) 732-5100
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Abstract
The Enforcement Integrated Database (EID) is a Department of Homeland Security (DHS) shared
common database repository for several DHS law enforcement and homeland security applications. EID,
which is owned and operated by U.S. Immigration and Customs Enforcement (ICE), captures and
maintains information related to the investigation, arrest, booking, detention, and removal of persons
encountered during immigration and criminal law enforcement investigations and operations conducted
by ICE, U.S. Customs and Border Protection (CBP), and U.S. Citizenship and Immigration Services
(USCIS), agencies within DHS. DHS personnel access the data in EID using the ENFORCE suite of
software applications: ENFORCE Apprehension Booking Module (EABM), ENFORCE Alien Detention
Module (EADM), and ENFORCE Alien Removal Module (EARM). The Privacy Impact Assessment
(PIA) for EID was published in January 2010 and last updated in September 2010. 1 ICE is now
deploying an upgrade to the ENFORCE applications, referred to as EARM version 3.0 (EARM 3.0), to
merge two of the ENFORCE applications, and to modify the data collected by DHS, the capabilities of
the software, and certain system interfaces. These changes require an update to the EID PIA.

Introduction
Within ICE, EID and the ENFORCE applications are used primarily by ICE personnel in the ICE
Office of Homeland Security Investigations and the Office of Enforcement and Removal Operations
(ERO), previously known as the Office of Detention and Removal Operations, to support ICE’s arrest,
detention, processing, and removal of aliens from the United States. This PIA update describes the
following changes to EID and the ENFORCE applications with the deployment of EARM 3.0:

1

•

Two new system interfaces were added and other changes have been made to EID to support
the electronic processing of immigration bonds;

•

EADM was retired and its functions have been merged into EARM;

See EID PIA and EID PIA Update at http://www.dhs.gov/privacy.

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•

Changes were made to EARM to enable ICE Health Services Corps (IHSC) personnel to
enter limited medical information into EID. (IHSC is an office within ERO that oversees
medical treatment of individuals in ICE detention (detainees).);

•

Changes were made to EARM to support the Alternatives to Detention (ATD) program;

•

Users logged into EARM now have single sign-on access to ICE’s Electronic Travel
Documents (eTD) System;

•

EARM’s interface with the Department of Justice’s Case Access System (CASE) has
changed; and

•

EARM’s Crime Entry Screen (CES) is also being deployed in EABM.

The following sections describe the above changes in more detail.
Electronic Bond Processing
Two system-to-system interfaces have been added that provide data to EID in support of the
electronic processing of immigration bonds. The first is an interface with ICE’s Electronic Bond Online
System (eBONDS) and the second is with ICE’s Bond Management Information System (BMIS).
eBONDS is a web-based application through which surety agents and ERO officers facilitate the
application for and granting of immigration bonds for detained aliens. (For more information on
eBONDS, please see the Electronic Bond Online System – Phase One PIA. 2) The basic function of
eBONDS is to allow surety companies to post immigration bonds online for aliens that ERO has
determined are eligible for release on bond. A surety agent logs onto eBONDS to request bond
verification for an alien from the relevant ERO field office. If the field office confirms the alien is
eligible for a bond, eBONDS retrieves information about the alien and the bond amount from EARM.
EARM also provides eBONDs with information about the surety company and Power of Attorney
information that it receives from BMIS via a system-to-system interface between the two systems. (For
more information on BMIS, please see the Bond Management Information System Web Version PIA. 3)
The confirmation with the information mentioned above is forwarded to the surety agent via eBONDS.
The surety agent completes, digitally signs, and submits an electronic immigration bond form (Form I-

2

See Electronic Bond Online System – Phase One PIA at http://www.dhs.gov/privacy.

3

See Bond Management Information System Web Version PIA at http://www.dhs.gov/privacy.

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352) to the relevant field office for approval. An ERO officer reviews the bond documentation package
in EARM for completeness and accuracy against the information in EARM and BMIS. If the bond
documentation package is complete and accurate, the ERO officer approves and digitally signs it in
EARM. EARM updates eBONDS, which notifies the surety agent via email that the bond has been
approved.
When a person wants to post a cash bond for a detainee, the obligor (usually a family member or
friend of the detainee) brings a cashier check or money order to the ERO field office. The ERO officer
verifies the alien’s custody status for release on bond and completes both the Form I-352 and the Form I305, a receipt for the money posted for the bond. The ERO officer then enters information from the
forms into EARM, which sends the information electronically to BMIS.

Retirement of the ENFORCE Alien Detention Module (EADM)
EADM is used by ERO officers to book detainees into and out of ICE detention facilities while
EARM supports ICE’s processing and removal of aliens from the United States. Having detention and
removal data in different modules is problematic because ERO personnel do not have an integrated and
comprehensive view of a detainee’s detention and removal information. In an effort to improve the
integration and operational flow of data within the detention and removal process, ERO is retiring EADM
and merging its data and capabilities into EARM. By combining the detention management capabilities
in EADM with the removal management capabilities in EARM, EARM 3.0 provides users an integrated
and comprehensive view of a detainee’s detention and removal status in a single application.
With the merger of EADM into EARM, changes have been made to improve data quality and
integrity. For example, business rules have been added to ensure that a detainee cannot have multiple
active detention records. Additionally, the capability to create and manage detainee travel manifests has
been moved to EARM. Business rules were added to ensure that a detainee is booked into a facility
before he or she is able to be added to a travel manifest. The business rule changes are designed to help
improve the quality of the data and prevent errors in detainee information.
Additionally, new capabilities have been added to EARM to help ICE enforce important
detention and management policies. For example, ERO policy allows a detainee to make a phone call
each time he or she is transferred to a new detention facility. In order to help ensure compliance with the
policy, the ERO officer manually enters information into EARM about the detainee’s phone call
including the person who was called, the person’s relationship to the detainee, the date and length of the
call, the phone number that was called, whether the call was successful, and any related comments.
Although not required by the policy, EARM 3.0 enables ERO officers to make a notation about other
phone calls that detainees make.

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EARM also reminds ERO officers of actions they need to take, such as allowing a detainee to
make a phone call or bringing a detainee to an appointment or office visit. Finally, multiple photos for a
detainee can now be uploaded allowing ERO officers to track changes in a detainee’s appearance
throughout the person’s interaction with ERO. Previously, only one photo could be uploaded.
Medical Screening Information
Prior to EARM 3.0, EID contained limited medical information relevant to a detainee,
specifically: an indicator whether or not there is a medical alert on the detainee, a general assessment of
the detainee’s apparent health (good or poor), and whether the detainee arrived with or without
medication. This information was entered in EADM or EARM by either IHSC personnel or by nonmedical ICE or detention facility personnel. With the release of EARM 3.0, IHSC users are able to input
additional medical information about detainees in IHSC-staffed detention facilities. Specifically, IHSC
personnel can create a new medical hold indicating medical-based restrictions on transporting detainees.
The hold is associated with business rules that will prevent detainees from being booked out of detention
facilities using EARM. IHSC users are also able to input the date detainees received or are scheduled to
receive their medical screening and indicate whether the screening is pending or complete.

Alternatives to Detention (ATD) Module
In FY 2002, Congress authorized the use of alternatives to detention programs as a mechanism to
facilitate alien compliance with attendance at immigration court hearings and departure from the United
States. The program allows certain aliens whose detention is not statutorily mandated to remain in their
communities while their removal process is pending. ERO’s Alternatives to Detention (ATD) program
meets this critical need for community supervision of the non-detained alien population using technology
and case specialists to actively engage aliens until a final determination of their immigration status can be
made.
The ATD program releases detainees (called “participants” in the ATD program) who are not
required by statute to be detained. Prior to enrollment in the program, ERO officers vet the individuals to
ensure that they are eligible to participate. Those who are eligible to participate choose whether or not
they want to participate in the program. Those who choose to participate sign the rules of participation
indicating their willingness to comply and those who do not want to participate are housed in a detention
facility. In EARM, ERO officers note those who choose to participate, the date the participant was
enrolled, and the type of supervision that the individual will receive.
ERO uses two approaches (called “components”) to supervise the participants in the program.
The first approach is the full-service component. This supervision is performed by an ERO contractor.
The ERO officer sends the contractor an enrollment form with the participant’s name, A-number, date of
birth, country of birth, contact information, and stage in the immigration court proceedings. In addition to
in-person visits, the ERO officer also tells the contractor if the participant will be subject to telephonic

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reporting or global positioning system (GPS) monitoring, to ensure that the participant remains within
authorized boundaries. One of the contractor’s case specialists enters the information provided on the
enrollment form into the contractor’s system that it uses to track participants. 4 The case specialist
interviews the participant and may collect additional information about the individual including gender,
height, weight, marital status, and address. The case specialist creates an individualized supervision plan
that describes when the case specialist will meet with the participant and when the participant must report
in.
The second supervision approach used in ATD is the technology-only component. Participants
with the technology-only component are overseen by ERO officers and not by the contractor’s case
specialists and case specialists are unable to access the records for these participants. The ERO officer
logs into the contractor’s system, creates the record for the new participant, assigns the appropriate
technology to be used, and sets all the monitoring provisions. Using the contractor’s system, ERO officers
monitor participants using either GPS monitoring devices or telephonic reporting.
Case specialists and ERO officers use the contractor’s system to record participant activities that
are relevant to the participant’s terms of release, such as meeting with case specialists. Additionally, the
GPS monitoring devices send information to the contractor’s system. The devices collect a participant’s
current latitude and longitude coordinates, the direction the person is moving, and the person’s current
speed every one to three minutes, and then relay the information to the contractor’s system every 30
minutes to four hours depending on how the devices are configured. The contractor’s system does not
display location information for all participants at one time. Instead, case specialists and ERO officers are
only able to see location information related to the participants assigned to their office and they can only
see the information for one participant at a time.
The contractor’s system contains information for participants currently in the ATD program and
for participants who were discontinued from the program up to six months ago. Records for inactive
cases older than six months are archived by the contractor. GPS data for archived records is retained for
one year and then deleted. There is no data exchange or interface between EARM and the contractor’s
system. Any information in the contractor’s system that an ERO officer wants to enter in EARM must be

4

The contractor supporting the ATD program also monitors individuals on supervised release for other federal,
state, and local law enforcement agencies. The contractor’s information technology system is completely separate
from ICE’s systems and is used to support all of its customers.

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entered manually. Typically, officers only copy information relevant to a participant’s participation in
the ATD program such as incidents of non-compliance with the terms of release (e.g., failure of a
participant to attend an in-person meeting). Detailed data from the GPS monitoring devices such as
latitude and longitude coordinates is not generally placed in EARM.
The EARM 3.0 release makes several changes to the ATD information in EARM. First, ERO
officers are able to input information regarding participants’ automobiles. Second, ERO officers are able
to input information from the “emergency reports” provided by the contractor regarding participants
receiving full-service supervision who have not complied with the rules of their supervision including
those having unauthorized absences, having absconded, or having been arrested. Finally, three new
reports related to ATD have been added. The ATD Eligible for Participation Report identifies candidates
for the ATD program. The Active ATD Participants Report identifies all participants currently in the
ATD program and the Inactive ATD Participants Report identifies all individuals whose participation in
the program has been terminated.
Electronic Travel Document (eTD)
The ICE Electronic Travel Document (eTD) system is currently used to generate travel
documents for aliens who are being repatriated to their country of citizenship. (For more information,
please see the eTD PIA. 5) EARM 3.0 enables ERO officers who are logged into EARM to view records
in eTD without having to log into eTD separately. While viewing a record in EARM, an ERO officer can
choose to view travel document information stored in eTD. The officer is automatically authenticated in
eTD and is able to view the travel document request and/or the issued travel document.
Executive Office for Immigration Review’s (EOIR) Case Access System (CASE)
With the release of EARM 3.0, the interface used to share data from CASE to EID is changing.
Previously, EID manually ingested immigration court scheduling information from CASE so that ERO
officers could view upcoming court dates for an alien. With the release of EARM 3.0, EARM and CASE
established a direct system-to-system interface through which EARM queries CASE to obtain the latest
information for a particular court case, as required by the user. With this new interface CASE data will
no longer be ingested and stored in EID.

5

See ICE Electronic Travel Document System PIA at http://www.dhs.gov/privacy.

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Crime Entry Screen (CES)
With the release of EARM 3.0, CES is available to EABM and EARM users. This enables users
at ICE, CBP, and USCIS to use CES and allows authorized users to enter criminal history information
into EID during the booking phase of an enforcement action. This also supports the generation of ICE
levels for an alien at an earlier stage of the enforcement process. The ICE Level information helps ICE
law enforcement personnel in the field prioritize their enforcement activities on high-priority criminal
aliens in line with ICE’s enforcement policies. (For more information on the CES and ICE Levels, please
see the Alien Criminal Response Information Management System (ACRIMe) & Enforcement Integrated
Database (EID) PIA Update. 6)

Reason for the PIA Update
The PIA for EID was last updated in September 2010, and reflected the system at that time. The
ENFORCE applications continue to be enhanced to support ICE’s changing business and operational
needs and the PIA is being updated to reflect those changes.

Privacy Impact Analysis
The System and the Information Collected and Stored within the System
As noted above, EID and the applications that use it capture and maintain information related to
the investigation, arrest, booking, detention, and removal of persons encountered during immigration and
criminal law enforcement investigations and operations. Enhancements have been made to the system to
enable it to collect additional information to better assist ERO personnel with the booking, detention, and
removal of aliens. Most of the new information is obtained from other systems and is not collected
directly from individuals.

6

See Alien Criminal Response Information Management System (ACRIMe) & Enforcement Integrated Database
(EID) Update at http://www.dhs.gov/privacy.

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Electronic Bond Processing
EID contains additional types of information related to electronic bond requests; however, none
of the new information is related to detainees:
• Information about forms submitted as part of the bond process including the date the form was
received, the document’s ID, the date it was reviewed, and by whom;
• Information about the bond including the date it was received, the document’s ID, the date it was
either approved or denied, and the person who either approved or denied it;
• Names of surety companies and their agents; and
• System identifiers for documents and individuals that enable data to be exchanged between
EARM and eBONDS and EARM and BMIS Web.
ENFORCE Alien Detention Module (EADM)
With the retirement of EADM, EARM was enhanced to provide an integrated and comprehensive
view of the information regarding a detainee’s detention and removal. Several new types of information
are being added to EARM as a result:
•

•

•

•

Previously, EARM could only store one photo of the detainee. EARM can now store multiple
photos of the individual and other images associated with the individual including images of
scanned documents or other objects.
Information related to the phone calls that detainees make:
o The person who was called;
o The person’s relationship to the detainee such as mother, brother, or attorney;
o Date of the call;
o Success of the call – whether the call went through or not;
o Length of the call;
o Phone number that was called;
o The ERO officer who allowed the detainee to make the call; and
o Any comments by the ERO officer related to the call.
System-generated reminders to ERO officers prompting actions such as allowing a detainee to
make a phone call or bringing a detainee to an appointment:
o Date when the task needs to be done;
o Indication that the task is either pending or completed; and
o Instructions for the task.
Information regarding the detainee’s detention:
o Indicator whether the detainee should be treated as a juvenile;
o Detainee’s assigned bed/unit; and
o Date when the detainee’s attorney was notified about the detainee being moved.

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Four reports currently in EADM are being moved over to EARM. The Current Detainee Report
shows detainees in ICE custody. The Man Days Report lists detainees and the number of days that each
detainee has been in detention at their current facility. The Hanging Transfer Report shows detainees
who have been transferred out of a detention facility but who have not yet been enrolled in another
detention facility. The Alert Code Report lists detainees who have an alert code assigned to them such as
“aggravated felon” or “dangerous – hostile toward law enforcement officers.” These reports function as
they did in EADM.
Medical Screening Information
As mentioned above, EID contains limited medical screening information about detainees. With
the EARM 3.0 release, IHSC staff are able to input into EID additional information regarding detainees in
IHSC-staffed facilities:
•

Medical intake and book-out screening date;

•

Screening status (pending or completed); and

•

IHSC medical alert and IHSC medical hold which indicate whether there are medical-based
restrictions on transporting the detainee.

ATD Module
As mentioned above, the ATD program enables ICE to supervise the individuals that have been
released into the community as part of the program. Below is the information that is stored in EID related
to ATD:
• Dates of enrollment in ATD and termination from the program including reason for termination
(e.g., person departed, person was removed, person has been granted an immigration benefit,
etc.);
•

Information used to evaluate the individual’s suitability for the program such as whether the
person is subject to mandatory detention or whether the person is a threat to national security or
public health or safety;

•

Indication whether the individual is assigned to the full-service component or the technology-only
component and the type of technology assigned;

•

Information regarding incidents involving participants with full-service supervision that have not
complied with the ATD requirements (e.g., those that have absconded, been arrested, or been
hospitalized). The information that is recorded is:
o

Date of the incident report;

o

Incident type;

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•

o

Location where the incident occurred;

o

ERO and ICE HQ authorities that were notified; and

o

Scanned images of documents related to the incident such as an arrest sheet.

Information regarding participants’ automobiles such as vehicle type (e.g., recreational vehicle,
motorcycle, bus, commercial vehicle), vehicle identification number, and license plate number.
There is also a free text field that allows the user to include other information related to the
vehicle.

Three new ATD reports have been created. As noted above, the ATD Eligible for Participation
Report identifies candidates for the ATD program and contains information about each individual
including:
•

Biographic information such as name, A-Number, country of citizenship, and date of birth;

•

Indication if the individual is a criminal and his or her aggravated felon code;

•

Information about the individual’s detention such as detention facility, book out or release reason
if the individual has been released, and the ERO office overseeing the individual’s case and
detention; and

•

Indication if there is an active bond for the individual, if it has been breached, and if there is a
final order of removal.

The Active ATD Participants Report identifies all individuals currently in the ATD program and includes:
•

Biographic information such as name, A-Number, country of citizenship, and date of birth;

•

Indication if the individual is a criminal and his or her aggravated felon code;

•

ERO office overseeing the individual’s case;

•

Indication if there is an active bond for the individual; and

•

Information related to the individual’s participation in the program including number of days,
enrollment date, and level of supervision.

The Inactive ATD Participants Report identifies all individuals whose participation in the program has
been terminated and includes:
•

Biographic information such as name, A-Number, country of citizenship, and date of birth;

•

Indication if the individual is a criminal and his or her aggravated felon code;

•

ERO office overseeing the individual’s case;

•

Indication if there is an active bond for the individual; and

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•

Information related to the individual’s participation in the program including number of days,
enrollment date, type of supervision, number of missed appointments, date the individual was
removed from the program, and the reason for removal from ATD.

Crime Entry Screen (CES)
With the release of EARM 3.0, users in both EARM and EABM are able to access CES and input
the following additional information:
•

Date of conviction;

•

Date the charge was dropped or dismissed;

•

Length of sentence;

•

Indicate whether a financial loss was incurred; and

•

Indicate whether the crime was against a minor.

Data Accuracy and Privacy Risks
The release of EARM 3.0 has not resulted in the creation of any new significant privacy risks.
Many of the changes provide additional information to personnel who have a need for it. For example,
combining the EADM and EARM information in one place or making the criminal history information in
the CES accessible in both EABM and EARM ensures that personnel have the information they need in
order to handle detainees appropriately.
As mentioned above, EARM 3.0 also implements new features that improve data accuracy. New
business rules help to ensure that data is entered accurately. Additionally, EARM now queries CASE
directly, meaning EID no longer ingests data from CASE. This reduces the proliferation of personally
identifiable information within government information systems and improves the currency of the
information available to ICE personnel regarding court schedules for detainees. This helps to reduce the
possibility of errors based on out-of-date court scheduling data.

Uses of the System and the Information
Externally, there is one new use of the data. The interaction of EID with BMIS Web and
eBONDS enables surety agents to post immigration bonds online and to receive notification that a bond
has been approved.
Internally, there are several new uses of the data. First, ERO officers use the electronic bond
processing enhancements to better route, process, and manage bond requests. Second, several of the
changes enable ERO to better manage the detention and removal of detainees, specifically the merging of

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EADM information into EARM, the accessibility of the CES from both EABM and EARM, and enabling
IHSC medical personnel to enter limited medical information including medical alerts and holds. Finally,
the functionality that has been added to support ATD enables ERO officers to better manage individuals
in the ATD program. The “emergency reports” provided by the contractor not only allow ERO officers to
identify participants who do not comply with ATD requirements, but also enable ERO personnel to track
program enrollment, provide statistical reporting, and reconcile invoices from the contractor. The new
ATD reports that have been added in EARM 3.0 also help ERO to manage participants in the program,
gather statistical information about the program, and calculate payment to the ATD contractor.

Retention
There are no changes to records retention as a result of this PIA update.

Internal Sharing and Disclosure
The release of EARM 3.0 has not resulted in any changes in the sharing of EID data with other
DHS components.

External Sharing and Disclosure
There have been two changes to how data is shared outside DHS. The first is that EARM sends a
query to CASE in order to retrieve immigration court scheduling information. The second is that EARM
shares data with surety companies via the eBONDS interface.

Notice
Most of the new information being collected in EID as a part of the EARM 3.0 release comes
from other systems that interact with EID; therefore, ICE is not in a position to provide notice at the time
of its collection. The agencies that collect this information, including ICE, are responsible for providing
appropriate notice, either on the forms they use to collect the information and/or through other forms of
public notice, such as Privacy Act System of Records Notices (SORN). The following SORNs are
published in the Federal Register and describe the data that EID receives from other systems as part of the
release of EARM 3.0:
System Name
BMIS Web and eBONDS

Agency
ICE

CASE

Department of
Justice
ICE

EID (EADM, EARM, EABM)

Systems of Records Notice
Bonds Management Information System
(BMIS), DHS/ICE-004, February 15, 2011, 76
FR 8761
Records and Management Information System,
EOIR-001, January 25, 2007, 72 FR 3410
Immigration and Enforcement Operational
Records System (ENFORCE), DHS/ICE-011,
May 3, 2010, 75 FR 23274

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Detainees are aware that ICE collects information about their phone calls. They are asked to
provide ERO officers with the name of the person to be called, the person’s relationship to the detainee,
and the phone number to be called and this information is noted in EARM. Detainees also receive notice
regarding their participation in the ATD program. Participants sign the rules of participation indicating
their willingness to comply with them. Individuals receiving technology-only oversight meet with an
ERO officer to discuss their supervision plan while individuals receiving full-service supervision are
interviewed by one of the contractor’s case specialists. The case specialist may collect additional
information directly from the detainee. It is important to note that any additional information that the
detainee provides to the contractor is voluntary.
Because EID receives some data from other systems and is a system used for law enforcement
purposes, individuals are unable to give their consent as to how their data is used because requiring
consent to the use of the data would compromise the system’s law enforcement purpose. All of the
information in EID is collected in order to help ICE with the booking, detaining, and removing of
detainees. There is a potential risk that the general public is not aware of the existence of EID. The
publication of the EID PIA, this PIA update, and the ENFORCE SORN mitigate this risk by describing
the types of individuals whose information is contained in the system, the types of data it contains, and
how the data is used.

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Individual Access, Redress, and Correction
There are no changes to the access, redress, and correction procedures described in the EID PIA
and subsequent PIA updates.

Technical Access and Security
The security features and access controls for EID have not changed. Please refer to the EID PIA
and subsequent PIA updates for more information.

Technology
The system is in the operations and maintenance phase of the software life cycle management
process. No technology is used that might raise privacy concerns.

Responsible Official
Lyn Rahilly
Privacy Officer
U.S. Immigration and Customs Enforcement

Approval Signature

_Original signed copy on file with the DHS Privacy Office._
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security