WASHINGTON, D.C. – All Voting is Local submitted a public comment to the Social Security Administration regarding the Social Security Administration’s Systems of Record Notice, strongly urging against adding permitting disclosure of citizenship and immigration information from the Master Files of Social Security Number to the U.S. Department of Homeland Security (DHS) because it will create a security risk for Americans’ personal data and information. Read the full comment below:
FOR: Tristin Dorsey
Government Information Specialist
Social Security Administration
FROM: All Voting is Local
DATE: December 11, 2025
RE: Social Security Administration’s Systems of Record Notice
[Docket No. SSA-2025-0225]
Thank you for the opportunity to comment on the modifications to the Master Files of Social Security Number (SSN) Holders and SSN Applications (60-0058). All Voting is Local (“All Voting”) is a nonpartisan organization that works on the ground in eight states for free and fair elections. In a moment of ongoing threats to our freedoms, All Voting advocates state and local officials for policies and practices that ensure the American people choose their leaders, not the other way around. All Voting submits this comment on the docket SSA-2025-0225 to urge against adding a “routine use” permitting disclosure of citizenship and immigration information to the Department of Homeland Security (DHS).
All Voting strongly urges against adding permitting disclosure of citizenship and immigration information from the Master Files of Social Security Number to the DHS because it will create a security risk for Americans’ personal data and information.
Background
In accordance with the Privacy Act of 1974, the Social Security Administration (SSA) issued “public notice of its intent to modify an existing system of records entitled Master Files of Social Security Number (SSN) Holders and SSN Applications (60-0058), last published on February 20, 2025.” They are proposing several changes, including adding a “routine use” that will “permit disclosure” of citizenship and immigration information to the DHS.
According to the SSA, the information in this system is used to assign SSNs and for a number of administrative and program purposes, including but not limited to: “for various Old Age, Survivors, and Disability Insurance; Supplemental Security Income and Medicare/Medicaid claims purposes; as a case control number; as a secondary beneficiary cross-reference control number for enforcement purposes; for verification of individual identity factors; and for other claims purposes related to establishing benefit entitlement”.
Sharing Social Security Administration data with the Department of Homeland Security risks disenfranchising American citizens.
In the past few months, the DHS has unlawfully created a new voter citizenship check system, which they are calling the “Overhauled Systematic Alien Verification for Entitlements (SAVE)” system. DHS is encouraging states to run their entire voter rolls through this new system, and the system is providing states with lists of individuals who DHS believes may be voting illegally. The SAVE system was not designed for tracking U.S. citizenship nor for verifying voter eligibility, and neither were the Master Files of Social Security Number. It’s a federal query system, initially designed to help verify the citizenship and immigration status of individuals who are applying for public benefits. The results are likely inaccurate for many voters, especially naturalized citizens.
States and counties who are working with DHS on using the new SAVE system are now improperly accusing eligible voters of being “noncitizens” and demanding that they prove their citizenship by showing their citizenship papers in order to be allowed to vote. Proving citizenship requires readily producing a birth certificate, passport, or similar documents, which are not easily accessible documents for many Americans. Connecting to the SSA does not fix this problem and amplifies issues of privacy related to the creation of the database. This will create additional barriers to voting and likely result in disenfranchisement of citizens who do not have the time nor the resources to complete an unnecessary and intrusive administrative process.
Expanding the use of the Master Files of Social Security Number will put American’s data at risk.
When Americans interact with the SSA, they only expect the citizenship information they share to be used for purposes related to benefits, retirement, disability, and death. Americans did not consent to their sensitive data being repurposed by federal or state governments for use in a massive voter verification system. The government has no right to repurpose their data this way, without consent.
The Privacy Act protects U.S. citizens and lawful permanent residents from improper government use of their data. This consolidation of data substantially increases risk of personal information being vulnerable to hacking or security breaches. Connecting the SSA’s database to the DHS creates particularly pointed risks. It threatens to subject Americans to unwarranted investigations and creates unprecedented security risks by placing millions of Americans’ sensitive, personal information in a single target-rich system.
Conclusion
The administration rushed head-first into making sweeping changes to the SAVE system, altered its intended purpose, and risked Americans’ privacy with the addition of SSA data. In summary, changes to the SAVE system include mixing federal data, such as Social Security numbers, requiring less individual information about a voter to create matches. Bulk uploads of potentially hundreds of thousands of voters are problematic and will lead to more voters being disenfranchised. The retooling of the SAVE system effectively supercharges an already flawed system. Here are five things you should know about the harm of the changes and retooling of the SAVE system and how it contributes to election interference:
- Retooling the SAVE system for voter list maintenance goes beyond its intended purpose.
- Retooling the SAVE system, without a thorough investigation into its ability to pool information accurately and reliably, blatantly disregards the impact on all voters.
- Retooling the SAVE system fuels the thoroughly disproved and debunked false narrative about widespread, intentional, and illegal voting; the number of noncitizens removed from rolls for ineligibility is typically less than 1% in states where removals have occurred —and in some instances, without confirming removal for illegal voting with the individual.
- Retooling the SAVE system is also a waste of time in terms of its outcomes (see #4), at a time when 76% of Americans are more concerned about political conflict and 56% about economic struggles.
- Retooling the SAVE system is nothing but a smokescreen for the administration to continue laying the groundwork for election interference and undermining elections—for all of us.
For the reasons outlined above, All Voting is Local strongly urges a rejection of the expanded use of data from the SSA to aid in voter verification as that was never its intended purpose.
Sincerely,
All Voting is Local