Department of Homeland Security
Attn: NAC 1-12037
Washington, D.C. 20538
RE: Notice of Proposed Rulemaking DHS-2006-0030
Dear Secretary Chertoff,
I am submitting this comment email in response to the Notice of Proposed Rulemaking DHS-2006-0030. I have thoroughly examined the Act in question, NPRM DHS-2006-0030, and, pursuant to 6 CFR Part 37 I am taking this opportunity to voice my objections to this program. I am a security professional with almost two decades of experience directly relevant to core issues of this program.
In short, after careful analysis I have concluded that implementation of the REAL ID Act:
- Violates Title XV Sub B Sec 1514 of the Homeland Security Act of 2002, which states, in whole, "Nothing in this Act shall be construed to authorize the development of a national identification system or card",
- Potentially suborns the violation of several provisions of the Privacy Act of 1974,
- Has grave implications for established safeguards for private citizens' data as defined in the Gramm-Leach Bliley Act of 1999, The Health Insurance Portability and Accountability Act of 1996, not to mention countless privacy components of regulatory and business contract standards in place throughout corporate America,
- Centralizes private identifiable information without appropriate security safeguards such that participants' information can (and most undoubtedly will) be exposed to stalkers, identity thieves, pedophiles, domestic abuse convicts, criminal organizations, and worse, and
- Opens heretofore unavailable avenues for fraud and abuse to criminals, terrorists and illegal immigrants wishing for a identification document one-stop shop.
It is for the above reasons, and more, that I add my voice to those calling for the rejection of this unnecessary, illegal, and potentially dangerous national identification system.