Comment Submitted to NARA Opposing the Destruction of Crucial Government Records About ICE Detention Abuses

Dear Ms. Hawkins,

The proposed records schedule, Docket No. NARA-2017-054, would allow the Department of Homeland Security’s Immigration and Customs Enforcement (“ICE”) to begin destroying crucial government records that detail “incidents of sexual abuse and assault, escapes, deaths while in agency custody, telephone rates charged to detainees, alternatives to detention, logs and reports on status of detainees and detention facilities, and location and segregation of detainees.” We write to express our deep disagreement with this agency’s preliminary approval of such a request by NARA Appraiser Ashby Crowder and stress upon NARA the importance of preservation of these documents which are critical to the public well-being.

In determining whether to approve destruction of federal records, the Archivist of the United States must “thoroughly consider the records’ administrative use by the agency of origin, the rights of the Government and of private people directly affected by the Government’s activities, and whether or not the records have historical or other value.” For each of these three reasons, and given the serious nature of these records, we strongly recommend that NARA deny ICE’s proposed records schedule.

Read the full comment here.

Please see this blogpost for more information. You can see the entire list of records that will be destroyed, and NARA’s reasoning for agreeing to the destruction, in the attachment. Now, here’s where you come in. The NARA is accepting public comment on this matter until Friday, September 15. Public comments can be very simple; it’s just a matter of letting our disapproval be on the record. Comments should be directly submitted to NARA at request.schedule@nara.gov, and you should use the following reference number: DAA-0567-2015-0013.

In addition to this, there is also another ICE document destruction proposal with NARA on the Federal Register. That proposal includes: records related to detention center inspections and sexual abuse prevention policy development, national detention center standards and records related to national detention center standards development and implementation. The deadline for requesting that proposal from NARA is September 25 and public comments are due 30 days later.

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