usrap overseas processing manual control number: integrity

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USRAP Overseas Processing Manual Control Number: v2.0 Integrity & Compliance [ 1 ] Integrity & Compliance Effective: 05 February, 2021 Version: 2.0 Approver: Nicole Patel Summary: This is the Integrity & Compliance module of the USRAP Overseas Processing Manual. For access to a link or to report a broken link, please contact the RPC Help Desk. All USRAP Overseas Processing Manual documents are for Resettlement Support Center (RSC) use only and are not for further or public distribution. Any information sharing is governed by specific limitations and requirements in the cooperative agreements, the Memorandum of Understanding with the International Organization for Migration (IOM), and this module. Any requests to forward outside your organization, including to your subsidiaries, should be made to your Program Officer. This guidance cannot be shared outside your organization without prior written approval by the Department of State’s Bureau of Refugees, Population, and Migration (PRM). Audience: RSCs (including RSC Headquarters as appropriate for monitoring purposes) Table of Contents: 1.0 Guidelines for the Treatment of Refugee Records .............................................................. 2 1.1 Terms Defined ...................................................................................................................... 3 1.1.1 Case Status Information Defined .................................................................................. 4 1.2 Records Covered .................................................................................................................. 5 1.3 Personally Identifiable Information (PII) ................................................................................ 5 1.3.1 Unique Identifier Chart .................................................................................................. 7 1.3.2 PII & SPII Determination Chart ..................................................................................... 7 1.3.3 Protecting PII/SPII ........................................................................................................ 9 2.0 General Principles Governing Access to Records ............................................................ 10 2.1 Authorized Unrestricted Access.......................................................................................... 11 2.1.1 Authorized Access to Applicant Records .................................................................... 11 2.1.2 Requests for Authorization ......................................................................................... 12 2.2 Authorized Limited Disclosures .......................................................................................... 12 2.2.1 Disclosure of Limited Information ............................................................................... 12 2.2.2 Disclosure of Limited Information to Non-RSC Interlocutors ...................................... 14 3.0 Data Sharing and Communication in the USRAP .............................................................. 24 3.1 Receiving, Sending, and Disclosing Applicant Data ........................................................... 24 3.1.1 Tableau Reports and START Filters (For RSCs Using START) ................................ 24 3.1.2 RSharenet .................................................................................................................. 25 3.1.3 Email/Written Communication .................................................................................... 25 3.1.4 Telephone/In-Person .................................................................................................. 27 3.1.5 Communication with Applicants .................................................................................. 28 3.2 Protecting Data ................................................................................................................... 30 3.2.1 Protecting Media ......................................................................................................... 30 3.3 Data Breaches .................................................................................................................... 30 3.4 Handling of Records ........................................................................................................... 31 3.4.1 Maintenance of Records ............................................................................................. 31

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Page 1: USRAP Overseas Processing Manual Control Number: Integrity

USRAP Overseas Processing Manual Control Number: v2.0

Integrity & Compliance

[ 1 ]

Integrity & Compliance Effective: 05 February, 2021 Version: 2.0 Approver: Nicole Patel

Summary: This is the Integrity & Compliance module of the USRAP Overseas Processing

Manual.

For access to a link or to report a broken link, please contact the RPC Help

Desk.

All USRAP Overseas Processing Manual documents are for Resettlement

Support Center (RSC) use only and are not for further or public distribution.

Any information sharing is governed by specific limitations and requirements in

the cooperative agreements, the Memorandum of Understanding with the

International Organization for Migration (IOM), and this module. Any requests

to forward outside your organization, including to your subsidiaries, should be

made to your Program Officer. This guidance cannot be shared outside your

organization without prior written approval by the Department of State’s

Bureau of Refugees, Population, and Migration (PRM).

Audience: RSCs (including RSC Headquarters as appropriate for monitoring purposes)

Table of Contents: 1.0 Guidelines for the Treatment of Refugee Records .............................................................. 2 1.1 Terms Defined ...................................................................................................................... 3

1.1.1 Case Status Information Defined .................................................................................. 4 1.2 Records Covered .................................................................................................................. 5 1.3 Personally Identifiable Information (PII) ................................................................................ 5

1.3.1 Unique Identifier Chart .................................................................................................. 7 1.3.2 PII & SPII Determination Chart ..................................................................................... 7 1.3.3 Protecting PII/SPII ........................................................................................................ 9

2.0 General Principles Governing Access to Records ............................................................ 10 2.1 Authorized Unrestricted Access.......................................................................................... 11

2.1.1 Authorized Access to Applicant Records .................................................................... 11 2.1.2 Requests for Authorization ......................................................................................... 12

2.2 Authorized Limited Disclosures .......................................................................................... 12 2.2.1 Disclosure of Limited Information ............................................................................... 12 2.2.2 Disclosure of Limited Information to Non-RSC Interlocutors ...................................... 14

3.0 Data Sharing and Communication in the USRAP .............................................................. 24 3.1 Receiving, Sending, and Disclosing Applicant Data ........................................................... 24

3.1.1 Tableau Reports and START Filters (For RSCs Using START) ................................ 24 3.1.2 RSharenet .................................................................................................................. 25 3.1.3 Email/Written Communication .................................................................................... 25 3.1.4 Telephone/In-Person .................................................................................................. 27 3.1.5 Communication with Applicants .................................................................................. 28

3.2 Protecting Data ................................................................................................................... 30 3.2.1 Protecting Media ......................................................................................................... 30

3.3 Data Breaches .................................................................................................................... 30 3.4 Handling of Records ........................................................................................................... 31

3.4.1 Maintenance of Records ............................................................................................. 31

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3.4.2 Retention and Disposition of Records ........................................................................ 32

4.0 Integrity and Compliance ..................................................................................................... 32 4.1 Roles and Responsibilities ................................................................................................. 32

4.1.1 RSC ............................................................................................................................ 32 4.1.2 Procedures for Responding to Allegations of Fraud or Malfeasance ......................... 34

4.2 Guidelines for Staff, Interpreters, and Workspaces ............................................................ 34 4.2.1 Staff Screening (international/national full- and part-time RSC employees) .............. 34 4.2.2 Translator, Interpreter, and Other Contractor Screening (contract, not RSC

employees) .......................................................................................................................... 35 4.2.3 Workspace Compliance .............................................................................................. 36 4.2.4 Visual Identification ..................................................................................................... 38 4.2.5 Electronic Systems and Processing Requirements .................................................... 38 4.2.6 Staff Orientation and Training ..................................................................................... 42 4.2.7 RSC Management Oversight ...................................................................................... 42

1.0 Guidelines for the Treatment of Refugee Records

Government records, including data and information on refugees, may not be used, disclosed, or

disseminated, except in connection with the administration of the U.S. Refugee Admissions Program

(USRAP) and only with the prior written consent of the Department of State. All sharing of individual

information is subject to the Privacy Act, 5 U.S.C. §552a, privacy policies of the Department of State and,

for Special Immigrant Visas (SIV), Section 222(f) of the Immigration and Nationality Act (INA), 8

U.S.C.§ 1202(f). In accordance with these laws and relevant implementing regulations, refugee records,

information, and data originating from WRAPS may not be shared, disclosed, or disseminated without

prior written consent of the Department of State, no matter whether those records, information, or data

have been transferred into another database and/or de-identified. Refugee data originating from the PRM

refugee case processing system may not be used for research purposes without the prior written consent of

the Department of State. The policies and regulations of other government agencies, including the

Department of Health and Human Services (HHS) and Department of Homeland Security (DHS), do not

replace or supersede the laws, regulations, and policies of the Department of State regarding restrictions

on the sharing of refugee records, information, and data. The Bureau of Population, Refugees, and

Migration (PRM) of the U.S. Department of State owns all data maintained in WRAPS except for

information and records in WRAPS originating from and owned by another U.S. government agency,

such as DHS.

PRM has compiled the guidelines below for all Resettlement Support Centers (RSCs) that process

applicants for refugee resettlement and SIV status in the United States with funding from PRM. Pursuant

to the cooperative agreements or Memorandum of Understanding (MOU) under which the RSCs

participate in the USRAP, all RSC employees must adhere to these guidelines.

The guidelines are intended to ensure that records on applicants, and affiliated persons, including U.S.

Ties, maintained by RSCs on behalf of PRM are treated in accordance with the requirements of U.S. law.

These laws include the Freedom of Information Act (FOIA), 5 U.S.C. §552; the Privacy Act, 5 U.S.C.

§552a; 5 FAM §469; and the Federal Records Management Statutes, 44 U.S.C. Chapters 21, 29, 31, and

33.

In addition, SIVs are covered by Section 222(f) of the INA, as amended; this is in addition to the

guidelines included below.

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RSC files and file rooms are covered by these guidelines as long as they contain USRAP files, even if

they also contain resettlement files for other, non-U.S. destinations. These guidelines apply as soon as an

RSC receives an application, whether or not the application is deemed complete and regardless of whether

the applicant is eventually approved for admission to the United States as a refugee. The guidelines also

apply to files opened on individuals who were eventually referred for resettlement in countries other than

the United States. Should an RSC have a separate facility/file room/location for non-U.S. resettlement

that does not include any USRAP files, that location is not covered by this guidance.

The guidelines in this document supplement the following published information:

The Foreign Affairs Handbook (FAH), including 5 FAH-4, Records Management Handbook, 100

and 300, related to the management and disposition of State Department records.

The Privacy Act Systems of Record Notice State-59, Refugee Case Records, published in the

Federal Register on February 6, 2012.

The U.S. Department of State Privacy Policy

The Refugee Processing Center Privacy Impact Assessment

The U.S. Department of State Records Schedule:

o Chapter 12: Refugee and Migration, including B-12-001-05, approved by the National

Archivist on August 28, 2008, under Records Disposition Authority N1-84-08-2; and

o Chapter 25: Population, Refugees, and Migration, including A-25- 003-03, approved May 30,

2008 under GRS20, Item 2 and N1-059-08-3. (Note: This chapter applies to PRM staff, not

RSCs.)

For SIVs, the Foreign Affairs Manual (FAM), including 9 FAM 203.5-3, Confidentiality in

Refugee, Asylee, V92, and V93 Casework.

RSC Inquiry Response Template

Third Party Authorization Form

USRAP Objectives and Indicators

RSC Style Guidelines

Questions or concerns related to refugee records should be addressed to the Program Officer in PRM’s

Office of Admissions (PRM/A).

1.1 Terms Defined

1. For the purposes of this document and the USRAP, “fraud” is defined as intentional deceit or

misrepresentation by a USRAP partner staff member, applicant, or other persons that is used to

benefit oneself or someone else through the USRAP.

2. “Malfeasance” is any intentional conduct that is wrongful or unlawful, conducted by a USRAP

partner staff member.

3. The term “applicant” includes individuals seeking admission under the USRAP, individuals

referred to the USRAP by others for consideration, and individuals seeking special immigrant

status who are eligible for travel and refugee benefits.

4. The terms “USRAP data,” “USRAP case management,” and “USRAP processing” include

data, the database, physical files, case documents, and processing of applicants, as defined

above, including SIV, Resettlement Agency (RA), and travel processing.

5. “Volunteer workers” includes all volunteer refugee assistants (e.g., incentive worker).

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6. The terms “applicant records” and “refugee records” refer to stored information (both

electronic and hard copy), including applications, supporting documentation, and

correspondence related to individual applicants.

7. “Research partner” refers to any third party—including an individual, academic institution, or

organization—that requests refugee records, data, or information for research purposes or that

RSCs or the International Organization for Migration (IOM) engages with for the purpose of

conducting research.

8. The “ordinary course of business” refers to RSC and IOM activities that are routine to fulfill

the terms of a cooperative agreement or MOU with PRM. Privacy Act Notice Systems of

Record Notice State-59, Refugee Case Records (“State-59”), covers records held overseas and

electronic records in WRAPS.

9. In these guidelines, a “need to know” is defined as when access to the information is necessary

for that party to conduct assigned duties related to the administration or implementation of the

USRAP.

10. “Access” includes visual inspection of the records, oral or written disclosures of information

from a record, or provision of copies of documents in a record. “Access” also includes bulk

dissemination of multiple records through reports generated from WRAPS data. (Reports on

refugee arrivals or other overview reports that do not include any personally identifiable

information (PII), are not restricted by these guidelines. Contact PRM/A for a separate

determination if there are access restrictions to specific reports.)

11. “Sharing” includes allowing visual inspection, providing oral or written disclosures, or

transmitting copies of refugee records or data.

12. “Remote access” and “remotely” include device(s) that are not physically part of the RSC

network, but connect to the aforementioned network (e.g., an RSC-issued device that uses a

private network (e.g. home network) to connect to the RSC network and/or WRAPS through a

Virtual Private Network (VPN)).

1.1.1 Case Status Information Defined

For the purposes of these guidelines, “case status information” may include:

Confirmation that an applicant has/has not been pre-screened.

Confirmation that an application is/is not currently being processed because the principal

applicant does/does not fall within categories of people currently being processed by the

United States.

Verification that specified documents/information/counseling must be received/conducted

to complete the applicant’s file or to attempt to resolve inconsistencies in the file.

Confirmation that the application has been approved or denied.

Reason for case closure if PRM conducted the case closure, except when case closure is

related to security checks.

The outcome of the USCIS decision only if the denial letter has been transmitted.

Other statuses as detailed on the RSC Inquiry Response Template and/or statuses approved

by the Refugee Coordinator (RefCoord) or Program Officer.

Under these guidelines “case status information” may not include:

Details of an individual’s personal history or characteristics, including details of the

persecution claim.

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Details concerning the substantive basis for actions taken on the application. This

restriction means, for instance, that someone who is authorized to receive only case status

information may not be told that a woman was raped during her escape from her country of

origin.

Results of any security checks on a case.

Any information regarding reasons for USCIS decisions (e.g., reasons for approval, denial),

beyond the information already provided in the decision letter. Note: If a decision letter has

not yet been provided to the applicant, the information in the decision letter should not be

provided to third parties.

Any information about security check processes under any circumstances.

Authorization to receive limited disclosures of information in applicant records does not

provide the recipient the authority to disclose information to persons who are not otherwise

entitled to receive it under these guidelines.

1.2 Records Covered

These guidelines apply to any information obtained by the RSCs from employees, contract workers,

volunteer workers, applicants, international organizations, or any other source that relates to

individuals identified for possible admission to the United States under the USRAP or SIV program.

The guidelines apply regardless of the form in which information is stored (e.g., paper or electronic

media).

As part of annual training, any RSC staff with access to physical and/or electronic records that

contain refugee data must acknowledge, in writing, having read the entire Integrity and Compliance

module. All RSC staff who use an RSC computer connected to the internet must annually

acknowledge, in writing, they have read the WRAPS Rules of Behavior, even if they do not have

access to the WRAPS database. This is due to the fact that the WRAPS Rules of Behavior contain

useful information about protecting the network/computer while using the internet. RSC Management

should keep a record of these acknowledgements to ensure staff compliance – an electronic

signature/record of acknowledgement is acceptable.

1.3 Personally Identifiable Information (PII)

PII is characterized as “any information about an individual maintained by an agency, including 1)

any information that can be used to distinguish or trace an individual's identity, such as name, social

security number, date and place of birth, mother's maiden name, or biometric records; and 2) any

other information that is linked or linkable to an individual, such as medical, educational, financial,

and employment information.

PII by itself, or when combined with specific identifying factors for an individual, may cause harm to

the individual. RSCs must protect all PII in their possession, whether it pertains to refugees, SIVs,

applicant relatives and relations, including U.S. persons and U.S. Ties, etc.

Some PII information when used alone may not appear to be identifiable to a person. However, such

pieces of information are considered PII because the information belongs to a real person, and if

combined with other PII information, could provide a substantial personal description of an

individual. Examples of PII, whether used alone or with other PII, include but are not limited to:

Full name, maiden name, mother's maiden name, or alias

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Personal identification number, such as social security number (SSN), passport number,

driver's license number, national ID number, or alien number

Contact information, including physical address, email address, or telephone numbers

Personal characteristics/biographic information, including photographic image (especially of

face or other identifying characteristic), fingerprints, handwriting, or other biometric data

(e.g., retina scan, facial geometry)

Information about an individual that is linked or linkable to one of the above (e.g., date of

birth, place of birth, race, religion, nationality, ethnicity, family relationships, geographical

indicators, employment information, medical information, etc.)

Sensitive PII (SPII) is PII, which if lost, compromised, or disclosed without authorization, could

result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. All SPII is

considered PII, however, not all PII is considered SPII. While both PII and SPII breaches should be

avoided using due caution (e.g. exercising good judgement and consulting your supervisor if you are

not sure whether to share something or how to store it), SPII requires additional security measures to

be taken. Specifically, all SPII must be encrypted when transmitted (see Section 1.3.1).

SPII consists of one or more pieces of information that are considered particularly sensitive on their

own as well as multiple pieces of PII that when combined become SPII. The following information is

considered SPII even when used alone because it is very clearly unique to the individual:

Social security number

National ID number

Driver’s license number

Passport number

Alien number

Biometric identification information

Note: Given the type and amount of personal information the following documents contain,

treat them as SPII and therefore ensure they are encrypted if emailed:

o Immigration or refugee processing documents – e.g. I-590

o Persecution claim history documents – e.g. Case History Template, USCIS Worksheet,

Request for Review (RFR), and UNHCR Resettlement Registration Form (RRF)

o Health information documentation – e.g. medical assessment forms, medical exam forms,

significant medical condition forms, and activities of daily living form

Groupings of information are considered SPII when they contain an individual's name (or other

unique identifier) plus one or more examples of non-sensitive PII. The following examples of non-

sensitive PII become SPII if a unique identifier is included with them:

Truncated SSN (such as last 4 digits)

Date of birth (month, day, and year)

Citizenship or immigration status

Ethnic or religious affiliation

Gender

Criminal history

Medical information

Examples of PII and SPII along with encryption instructions are provided in the charts below. This

list may not include all possible examples of PII or SPII regarding applicants and applicant relations.

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When in doubt, play it safe by encrypting the transmission, or ask your supervisor or the RPC Help

Desk for clarification.

1.3.1 Unique Identifier Chart

Types of Unique Identifiers

(these are “unique” because

they belong to only one person

in the world)

Constitutes SPII when used

alone

Constitutes non-sensitive PII

when used alone

Name (full or partial) X

Social Security Number (full #) X

National ID number X

Driver’s license

number/document X

Passport number X

Alien registration

number/document X

Biometric identification

information (including photo) X

1.3.2 PII & SPII Determination Chart

Types of PII

Non-Sensitive PII:

Does not require

encryption when

used alone or with

other non-sensitive

PII

Sensitive PII:

Requires encryption

when used alone (i.e.

is sensitive alone)

Sensitive PII:

Requires encryption

when paired with

name or other

unique identifier (i.e.

is sensitive when

paired with unique

identifier)

Social Security

Number (SSN) X

National ID

number/document X

Driver’s license

number/document X

Passport

number/document X

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Alien registration

number/document X

Biometric

identification

information

X

Applicant photographs X

Immigration or refugee

processing documents X

Persecution claim

history documentation X

Health information

documentation X

Truncated SSN X X

Date of birth or place

of birth X X

Citizenship,

nationality, or

immigration status

X X

Ethnic or religious

affiliation X X

Gender X X

Family relationships X X

Criminal History X X

Results of security

checks or interviews X X

Results of DNA testing X X

Employment or

education history X X

Contact information

(physical or virtual

address)

X X

Significant medical

condition X X

Basic medical

information X X

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Practices for handling PII depend on accessibility to the information, including level of access:

1. electronically (e.g., on WRAPS or through email communication) or

2. in hard-copy (e.g., printed notes, completed forms such as but not limited to I-590, AOR,

UNHCR Referral, and Medical Exam Forms).

Please refer to relevant sections of this document for further details on required practices for

handling PII according to level of access to records and methods of transmitting records.

1.3.3 Protecting PII/SPII

Documentation Classification and Storage Requirements

All documentation containing PII – both non-sensitive and sensitive PII – should be placed in the

RSC’s highest document “classification” category. Such documents should be stored in secure

physical and encrypted electronic locations that are only accessible to those with a need-to-know

for business operations.

Encryption Requirements for WRAPS and Applicant Data

All USRAP partners, including RSCs, RAs, UNHCR, IOM, panel physicians, etc. are required to

encrypt Sensitive PII (SPII) transmitted over email. This includes encrypting emails with SPII

between RSC staff within the same RSC, between RSCs and PRM or USCIS, between the RSC

and applicants when practical, etc. SPII in emails can be encrypted by 1) using an email software

with an encryption feature that has been approved by RPC Security for encryption, or 2) moving

SPII information into an attachment using a separate software that complies with FIPS 140-2

cryptographic specifications. It is a best practice for RSCs to minimize the amount of PII and

SPII sent via email, especially for internal communications, and instead leverage

WRAPS/START, discuss cases by only referencing their case numbers, or place SPII in a shared

drive or RSharenet and refer colleagues to that location to access the information. If SPII must be

included in an email communication to any party, it should be encrypted.

Option 1: Email software with an approved encryption feature (Note: if using an email software

with an encryption feature, the ‘encrypt’ option needs to be selected before sending - emails are

not automatically encrypted):

Microsoft Office 365 - Office 365 Message Encryption (OME)

Microsoft Office 365 and Outlook - S/MIME encryption

Option 2: Attachment encrypted with FIPS 140-2 compliant encryption software:

WinZip 18.5

WinZip Courier version 7.0

WinZip Enterprise

Microsoft Office - “Encrypt with Password” feature

Adobe Acrobat - “Encrypt with Password” feature

Adobe Acrobat and Adobe Reader - FIPS Mode

RSCs should note that simple case status updates in accordance with the standard RSC Inquiry

Response Template and case numbers do not constitute PII and thus do not require encryption.

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RSCs should limit to the extent possible the transmission of PII in their communications with

refugee applicants, petitioners, congressional inquiries, and other authorized parties. Only the

minimum necessary identifying information should be included in their communications and case

status updates with authorized parties.

All USRAP partners are required to comply with encryption requirements. RSC staff should

report to the RSC Director or Deputy, or through other identified internal processes, any USRAP

partners who refuse to comply with encryption requirements. In all responses to the original email

that contains unencrypted SPII (from partners or from an applicant), either redact all SPII from

the response chain or follow encryption guidelines if necessary to encrypt the email or

attachment.

As discussed in Section 1.3, the names of applicants and applicant relations (including partial and

full names) are PII but are not considered SPII on their own. However, if the name is combined

with other PII specific to the applicant or applicant relation, this is considered SPII and must be

encrypted if transmitted. For example, if a list comprised just of applicant names is to be emailed,

it is simply PII and encryption is not required. However, if a list of applicant names also includes

date of birth information, the list becomes SPII and must be encrypted before sending. Note:

WRAPS case numbers are not PII. RSCs are encouraged to use case numbers to reference cases

so that PII does not need to be shared.

If an email contains many examples of non-sensitive PII, it is a best practice to err on the side of

caution and encrypt the email even though it does not strictly contain sensitive PII. A multitude of

even non-sensitive PII information can provide a recipient who has malicious intent with enough

information about an applicant to cause damage.

2.0 General Principles Governing Access to Records

The governing principle of these guidelines is that information about applicants and approved refugees

and SIV holders can generally be disclosed only as specifically necessary to process the individual’s

application for admission to the United States. RSC employees, contractors, and volunteer workers may

have access to records only to the extent necessary for them to perform their duties, otherwise referred to

as “need to know.” They may disclose information to third parties only when the third party is authorized

to receive the information under these guidelines and has a “need to know,” or where PRM provides prior

written authorization.

No access may be given to applicant records or information derived from these records except in

accordance with these guidelines. “Access” includes visual inspection of the records, oral or written

disclosures of information from a record, or provision of copies of documents in a record. “Access” also

includes bulk dissemination of multiple records through WRAPS-generated reports. (Dissemination of

WRAPS-generated and other reports on refugee arrivals or other overview reports that do not include any

PII does not constitute “access” to records and is not restricted by these guidelines. Contact PRM/A for a

separate determination if there are access restrictions to those reports.) See Section 1.3 for information on

PII.

The guidelines are intended to give RSCs operational guidance to supplement the FAM, FAH, State-59,

and the U.S. Department of State Records Schedule (links in Section 1.0). If an RSC perceives an

inconsistency between these guidelines and other published information, the RSC should bring the

difference to the attention of the RefCoord and Program Officer responsible for the RSC’s geographic

region.

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2.1 Authorized Unrestricted Access

For the purposes of these guidelines, “unrestricted access” means authority to examine and copy any

information in the file for the purpose of carrying out duties for the USRAP or for other authorized

U.S. government business. “Unrestricted access” does not include authority to disclose information to

persons who are not otherwise authorized to receive it under these guidelines.

2.1.1 Authorized Access to Applicant Records

The following people are authorized, as described below, to access applicant records in various

forms:

2.1.1.1 Resettlement Support Center (RSC) Employees

The RSC Director, Deputy, and RSC processing managers are authorized to have unrestricted

access to applicant records in all forms.

For all other RSC processing staff, access must be limited to those records that the staff

member requires to execute his/her job responsibilities. See Section 2.2.1.1.

Any other RSC employee seeking unrestricted access must receive written individual

approval from the local or regional RefCoord after the RSC Director has certified the

employee’s need to have unrestricted access.

2.1.1.2 Department of State Employees

All U.S. Embassy personnel with responsibilities that fall under the USRAP; all PRM and

U.S. Embassy personnel with responsibility for refugee admissions or SIV work; other

Department of State personnel and contractors who have a demonstrated need for unrestricted

access, as determined by PRM.

2.1.1.3 Local U.S. Embassies

RSC management and employees are not permitted to communicate with U.S. Embassies

regarding SIV and refugee case applicants and information, except through the RefCoord or

identified Consular Officer in the Consular Section of the U.S. Embassy in that

country/region.

2.1.1.4 Department of Homeland Security (DHS) Employees

All DHS personnel with responsibility for the USRAP; and other DHS personnel who have a

demonstrated need for unrestricted access, as determined by the Department of State/PRM.

2.1.1.4.1 USCIS

RSC management and employees are permitted to communicate with USCIS (including

all sections of USCIS) regarding refugee case applicants and information, where such

communication is part of routine USRAP processing and on a need to know basis.

Requests for information from USCIS which fall outside normal USRAP processing

steps should be reported to the RefCoord, even if they do not specifically violate USRAP

data sharing and communication guidelines set forth in Section 3.0.

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See the Case Management module section on Case Information Exchange with USCIS

for more information on sharing data with USCIS. The RSC should use discretion to

determine if a request falls outside normal USRAP processing and should consult with

the RefCoord if a request falls outside normal USRAP processing.

2.1.1.5 Other U.S. Government Agencies

Representatives of other U.S. government agencies with a responsibility for the USRAP who

have a demonstrated need for unrestricted access, as determined by the Department of

State/PRM.

2.1.1.6 Security Vetting Partners (Non-USCIS)

RSC management and employees are permitted to communicate with security vetting partners

regarding refugee case applicants and information. RSC-specific communication with

security vetting partners should be in line with programmatic requirements (e.g. see Section

2.1.2.3 in the Case Management module on Central America Vetting). All requests for

information from security vetting partners should be shared with the RefCoord, even if they

do not specifically violate USRAP guidelines. Communications with USCIS security entities

should follow the guidance in Section 2.1.1.4.1.

2.1.2 Requests for Authorization

The RSC should refer any unauthorized request for access to an applicant’s records to the

RefCoord. The RefCoord is responsible for requesting PRM’s determination that individuals not

already afforded unrestricted access above have a need to know in order to perform their job

function.

2.2 Authorized Limited Disclosures

2.2.1 Disclosure of Limited Information

In general, RSCs can release only the information necessary for its partner or requestor to

perform its processing function and/or in response to its inquiry, as permitted in the guidelines

below.

2.2.1.1 RSC Employees, Contractors, and Incentive Workers Not

Authorized Unrestricted Access

RSC employees authorized for limited access to records should be given access/permissions

commensurate to those needed to perform their job function. The RefCoord must approve the

employee’s access type based on the employee’s job function in consultation with the RSC

Director and/or Deputy. This approval is subject to such terms and conditions as the

RefCoord may specify in order to ensure that the employee has access only to information

needed to perform the specific job. Note: For RSCs using START, the RefCoord, PO, and

RPC Policy, Performance, and Training Team will review and approve RSC staff’s

permissions in START.

Interpreters, translators, and other assistants, including contract workers or volunteer refugee

assistant, hired or contracted by an RSC, may be given access to information in applicant or

SIV records to the extent necessary to permit them to perform their duties, as determined by

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the RSC Director or Deputy. This also applies to interpreters, translators, and other assistants

supplied by other governments in accordance with arrangements made between the United

States and the other government. They may not be given electronic access to WRAPS unless

specifically authorized by the PRM/A Overseas Section Chief and RPC Director.

2.2.1.2 Other U.S. Government Employees and Contractors

An employee or contractor of the U.S. government not authorized unrestricted access may be

given information needed to perform a specific job function if PRM determines they have a

demonstrated need to know, subject to such terms and conditions as PRM may specify to

ensure that the employee has access only to such information as they need to know to

perform the job. If the RSC is unsure of the U.S. government employee’s need to know or job

function and/or why the information is needed, the RSC should contact the RefCoord and/or

Program Officer for further clarification and/or permission to release the information.

2.2.1.3 International Organization for Migration (IOM)

RSCs may release information from the record of an applicant or SIV to an authorized IOM

representative to the extent necessary to allow IOM to carry out medical examinations, make

travel arrangements for the applicant or SIV, or complete other processing tasks requested by

the U.S. government under the MOU between PRM and IOM. If panel physicians are used in

lieu of IOM medical staff, the same principles apply. Information may be released only to the

extent necessary to carry out the medical examination and facilitate any other related

processing requirements.

RSCs are permitted to communicate with IOM Migration Health Division (MHD), IOM

Operations (Ops), and Panel Physicians regarding refugee applicants or SIV holder and

information in the course of routine USRAP processing and on a need to know basis.

Requests for information from IOM MHD, Ops, or Panel Physicians, or other entities, which

fall outside normal USRAP processing steps should be reported to the RefCoord, even if they

do not specifically violate USRAP data sharing and communication requirements as set forth

in Section 3.0.

2.2.1.4 Resettlement Agencies (RAs) Participating in the PRM-

Funded Reception and Placement (R&P) Program in the

United States

The guidelines in this section apply to information that RSCs may share with RAs in the

United States and their affiliate offices.

2.2.1.4.1 Information on all USRAP Cases

RSC management and employees are permitted to communicate with RA representatives

and affiliates regarding refugee or SIV holder applicants and information in the course of

routine USRAP processing and on a need to know basis. Requests for information from

RA headquarters/affiliates which fall outside normal USRAP processing steps, or if the

RA or affiliate’s need for the information is unclear, should be reported to the RefCoord,

even if they do not specifically violate USRAP guidelines.

The RSC is permitted to correspond with, provide updates to, and request further

information from a U.S. point of contact/petitioner, either directly or through a

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resettlement affiliate or agency, who is filing a petition on behalf of their foreign relative

in certain P2 categories and all P3 categories. No third party authorization is needed to

interact with, provide updates to, or request further information from the U.S. point of

contact and/or resettlement affiliate or agency assisting the petitioner filing for:

P2 Lautenberg Specter applicants in Iran

P2 Lautenberg applicants

P2 I-130 Iraqi and Syrian applicants

P2 Iraq applicants

P3 applicants: DNA testing, AOR discrepancy letters, AOR rejection letters, and

RAVU decision letters

Once the above P2 and P3 cases have been interviewed by USCIS, the RSC should

advise the U.S. points of contact and resettlement agencies that the RSC may not provide

any further information on the case, including case status, without a written third party

authorization from the refugee applicant.

Resettlement agencies and affiliates may receive further information and case status

updates on all cases when the case is allocated to or assured by the RA without a specific

third party authorization.

2.2.1.4.2 Information Sharing during Allocation/Assurance

During the allocation process, after USCIS has approved an applicant’s admission to the

United States either conditionally or finally or if otherwise instructed by PRM/A, the

RSC or the Refugee Processing Center (RPC) may release to the RA to which the case

has been allocated, for refugees or SIV holders, the following: the applicant’s name, age,

family relationships, place of birth, alien number, citizenships, aliases, ethnicity, religion,

nationality, country of asylum, UNHCR submission category, general health condition,

languages, English language ability, U.S. tie information, cross reference information

(hard and soft), dates of commencement and completion of CO training, projected date of

departure for the United States, and other biographic and personal data concerning the

applicant’s special resettlement and placement needs to ensure the refugee applicants or

SIV holders can be received appropriately on arrival in the United States. This can also

include case status information. Such information may also include information on

medical conditions so the RA may plan for special medical interventions upon arrival.

The RSC and RPC should not share any further information with the RA, other than the

information listed above, without consultation and concurrence with PRM.

Following assurance, RSCs may respond to inquiries from the RA in the United States

which has assured the case to respond to case status inquiries and facilitate processing of

the case.

2.2.2 Disclosure of Limited Information to Non-RSC Interlocutors

RSCs have the responsibility to abide by PRM data sharing, communications, and privacy

guidelines and policies in all communications, both internal and external, as set forth in Section

3.0. In the event the RSC receives communications from an outside source which does not abide

by, or violates those guidelines and policies, they should ensure any/all responses still maintain

all applicable communications and privacy guidelines and policies. If the RSC finds one or more

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of its employees has intentionally and/or maliciously violated these guidelines and policies, take

the appropriate disciplinary action and report the issue to the RefCoord immediately.

Specific attention should be paid to the restrictions regarding refugee applicant communications

in this document. Requests for information from refugee applicants which fall outside normal

USRAP processing steps should be reported to the RefCoord, even if they do not specifically

violate USRAP guidelines.

Beyond RSC employees, contractors, and USRAP partners listed in Sections 2.1 and 2.2.1, the

following groups and individuals may be given the right to receive certain USRAP data to

perform a processing function and/or in response to an inquiry. Further information and details on

permissions for these groups can be found below.

1. Applicants, their family members, or other affiliated third parties

2. Attorneys or Accredited Representatives

3. United Nations High Commissioner for Refugees (UNHCR)

4. Heads of RSC Parent Organizations and their Designees

5. Foreign Government Authorities

6. The International Committee of the Red Cross or the American Red Cross (ICRC)

7. Mental Health and Other Counseling Organizations

8. Members of Congress

9. U.S. Government Law Enforcement Entities

10. Non-USRAP Non-Governmental Organizations (NGOs)

11. Media

12. Research

2.2.2.1 Applicants, Family Members, or other Third Parties

RSC employees cannot reveal information regarding the processing status of the refugee

application except as provided herein. A refugee applicant, Follow-to-Join Refugee (FTJ-R),

or SIV applicant may make an inquiry to the RSC concerning the status of their case. FTJ-R

applicants may inquire to an RSC regarding their case under the same guidelines as other

USRAP applicants. The RSC may respond to an FTJ-R inquiry if the RSC is processing the

FTJ-R case. If the FTJ-R case is processed by a U.S. Embassy or Consulate, the RSC should

refer the inquiry to the Consular Section of the relevant U.S. mission. The RSC should not

confirm nor deny the status of the case.

2.2.2.1.1 Applicants with a Shared Email Address

For applicants who share an email address with other, separate individuals not included

on the applicant’s case and/or included in a separate refugee application, the RSC should

make a good faith attempt to establish the identity of the respondent before providing a

case status update. The RSC should strongly encourage all refugee applicants to establish

separate email addresses not accessible to third parties or extended family. Applicants

who share an email address are required to acknowledge the sharing of personal

information. The language of the waiver should resemble the following and the RSC can

determine its own method for receiving and documenting this acknowledgement:

“I take full responsibility for protecting the privacy of my email communications. I

request that the RSC continue to send my confidential case information to

[email protected], although other people may have access to this email account.”

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2.2.2.1.2 Third Party Communication and Authorization

An applicant may elect to sign an authorization for another individual (non-case member)

to receive a case status update on their case. RSC should print the Third Party

Authorization Form on standard RSC letterhead. In the absence of a Third Party

Authorization Form, responses to inquiries or information sharing from an applicant’s

friends, acquaintances, relatives, or others must be limited to general descriptive material

about the USRAP or a description of program procedures that might be of assistance to

the inquirer, and should not confirm or deny that an applicant is in the USRAP pipeline.

FTJ-R petitioners should be treated the same as any other third party family member and

must have written authorization from the applicant before receiving case status

information.

If the third party has a signed Third Party Authorization Form from the refugee applicant

allowing information to be shared with certain family member(s), or with friends in the

case of the P2 Lautenberg Specter program, uploaded into WRAPS, the RSC may

provide those individuals with general case status information. If the form is received in

person, then the RSC staff member should sign the RSC Staff Signature section. Case

status information can be reported as listed in the RSC Inquiry Response Template,

and/or statuses approved by the RefCoord or Program Officer.

Inquiries for other information, apart from what is authorized under Section 1.1.1,

regarding specific refugee cases may not be provided to third parties, even if the

individual has a signed Third Party Authorization Form. For example, the RSC is not

permitted to provide copies of documents to an authorized third party. An authorized

third party is not permitted to accompany a refugee applicant to RSC intake or prescreen

appointments or engage in other types of involvement in refugee processing, except as

described below on Applicants with Impediments.

If the Third Party Authorization Form is received electronically, upload the email

coversheet in addition to the Form in WRAPS. The RSC is not required to print the Third

Party Authorization Form, if received electronically. Additionally, the RSC Staff

Signature section may remain blank if the form is received electronically.

If the person with the third party authorization is not related to the applicant (e.g., non-

family, non-U.S. Tie), the RSC should ask the applicant for an explanation of who the

person on the authorization is, and why that person should be able to receive the

authorization. The RSC should counsel the applicant on the significance/meaning of

Third Party Authorization. Following that discussion, the RSC supervisor should sign the

third party authorization, in addition to the applicant. The RSC supervisor signature is a

measure to ensure applicants fully understand that they are providing their case

information to a third party, as well as a fraud check for RSC employees. If the form is

received electronically, the RSC supervisor must review the form, but is not required to

sign the form. Upload the form in WRAPS, as well as the email from the RSC supervisor

confirming they reviewed the request.

2.2.2.1.3 Documents from Third Parties

The RSC is permitted to receive documents from authorized third parties, including

attorneys, who are writing on behalf of the refugee applicant. The RSC is also permitted

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to confirm receipt of the documents and/or engage in simple communication regarding

document submission and retrieval.

If the RSC receives documents that have relevance to a case (e.g., poison pen letters,

unexpected custody documents, etc.) from an unauthorized third party, the RSC should

upload the documents to WRAPS and notify PRM and the USCIS Desk Officer. If the

unauthorized third party is simply providing information regarding a case, RSC or PRM

personnel may forward the information about the case provided by the inquirer to the

appropriate processing entity if doing so may help facilitate the processing of the case.

2.2.2.1.4 Applicants with Impediments

An authorized third party is permitted to accompany a refugee with an impediment, such

as age, illness, or disability that prevents an applicant from communicating (speaking,

understanding, asking) independently, to RSC intake, prescreening, USCIS interview,

and other processing activities. During the first appointment, the third party should

complete a Third party Authorization Form and RSC staff should note the disability that

prevents the applicant from communicating independently. Third party authorization

forms are not required for refugee applicant on the same case as the applicant with the

disability. Forms are required for any third party not on the same case.

If an applicant has a serious impediment, minimal case status information may be

provided to a third party if the applicant has signed an authorization indicating which

individual(s) have permission to receive the information. If the applicant is not capable of

signing due to disability or illiteracy, an adult who is included on the applicant’s

application for admission or on a cross-referenced case may sign the authorization on

behalf of the applicant.

In the case of child applicants under the age of 14, or unable to sign due to illiteracy, an

adult guardian or relative may sign on behalf of the child. The adult must annotate on the

Third Party Authorization Form their relationship, and why the applicant is not able to

sign for themselves. RSC staff (or Consular officers for FTJ-R and SIV cases processed

at a U.S. Embassy or Consulate) should exercise common sense and caution in

responding to such inquiries and should only provide the minimum information necessary

to respond to the inquiry, and only with the signed authorization of the applicant.

2.2.2.1.5 Other Case Members

The RSC is permitted to share the reasons for administrative case closure with an

applicant or any case member if the case closure was made by PRM (e.g., petitioner

could not demonstrate qualifying employment, petitioner is deceased). Similarly, adult

children who marry and thus lose access to the qualifying family relationship can also be

counseled as to the reasons for the case closure. In cases where a case is administratively

closed for security reasons, the RSC can provide only the case closure language provided

to the principal applicant at the time of closure. The RSC is expressly forbidden from

providing security information directly to applicants or any third parties under any

circumstances.

The RSC is permitted to share only the outcome, but not additional details, of the USCIS

decision with an applicant or any case member. This is limited to information that a case

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is processing/moving forward to another processing step or has been denied if (and only

if) the denial letter has been transmitted.

For more information on sharing documents and case status information with applicants,

family members, or other affiliated third parties, see Section 3.1.4 on communication

with applicants.

2.2.2.2 Attorneys or Accredited Representatives

Written (including e-mail) and in-person inquiries to an RSC for case status information from

attorneys or accredited representatives1 may be answered with the requested information, if

the request is accompanied or preceded by a properly completed and signed G-28 or G-28I

Form, which is issued by DHS. (This form is in lieu of the Third Party Authorization Form,

for third parties who are not attorneys or legal representatives.) G-28/G-28I Forms are

available at https://www.uscis.gov/g-28 and https://www.uscis.gov/g-28i. Other information

regarding specific refugee cases beyond their case status may not be provided. RSC should

treat attorneys and representatives the same as any other third party with a signed waiver on

file.

For example, an authorized attorney may not inquire as to the reason a refugee applicant has

been deemed ineligible for P-2 access. The information that can be provided to an authorized

third party is limited to case status information detailed in Section 1.1.1. Further, except in

the case of Iraqi refugee applicants seeking admission through certain P-2 categories,2 an

authorized third party (including an attorney) is not permitted to accompany a refugee

applicant to RSC intake and prescreen interviews or engage in other forms of involvement in

refugee processing.

The G-28 or G-28I Form must include complete information, including signature from the

refugee applicant, as well as complete information, including signature from the relevant

third party. RSCs should ensure that the applicant’s signature on the form is verified against

his/her signature on file, if available. Responses to case status inquiries may only be sent to

the physical address or email address provided in the original G-28 or G-28I Form. If an

attorney or accredited representative provides on the G-28 or G-28I Form a general email

address that is accessible by other individuals (i.e., [email protected]), the RSC should

request a private email address for the attorney or accredited representative and should only

use that private email address for electronic communication. Case status information in

response to telephonic requests from third parties may not be provided.

1 A person who is approved by the Board of Immigration Appeals (the Board, or BIA) to represent aliens before the

Immigration Courts, the BIA and U.S. Citizenship and Immigration Services. They must work for a specific

nonprofit, religious, charitable, social service, or similar organization. The organization must be authorized by the

Board to represent aliens.

2 The National Defense Authorization Act of 2014 includes provisions authorizing Iraqi refugee applicants seeking

P-2 access pursuant to the Refugee Crisis in Iraq Act to be represented by attorneys or accredited representatives

during the refugee application process, including relevant interviews and examinations. Iraqi P-2 I-130 applicants

are not covered by this provision.

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There is not a defined validity period for the G-28 or G-28I.

2.2.2.3 United Nations High Commissioner for Refugees (UNHCR)

RSCs may release individual case information to an authorized representative of UNHCR to

the extent necessary to facilitate the processing of the case. The RSC is authorized to provide

feedback to UNHCR on its resettlement referral processes, provide information to allow

UNHCR to respond to deferred refugee referrals, and provide case status updates on an

individual case for the purpose of resettlement processing and refugee protection. RSCs may

not provide UNHCR with more information about the status of an applicant’s security checks

than the RSC would normally provide to the applicant (see Section 3.1.5.3 for more

information). Instead, RSCs may give UNHCR a general description of the security check

process that all refugees undergo. RSC management and employees are permitted to

communicate with UNHCR regarding refugee case applicants and information in the course

of routine USRAP processing and on a need to know basis. Requests for information from

UNHCR that fall outside normal USRAP processing steps should be reported to the

RefCoord, even if they do not specifically violate USRAP data sharing and communication

requirements as set forth in Section 3.0.

2.2.2.4 Heads of RSC Parent Organizations and their Designees

The immediate supervising official(s) of the RSC Director for the organization which runs the

RSC are permitted to have access to physical applicant files only for the purpose of

monitoring and evaluating the performance of RSC staff and leadership. Other employees and

leadership of the organization which runs the RSC, but who are employed outside the RSC,

are not authorized to access applicant records in any form without explicit prior written

permission from PRM/A. Electronic access to refugee information by the RSC parent

organization is not permitted without explicit prior written permission from PRM/A.

Individuals from the RSC parent organization with electronic access to refugee information

should acknowledge in writing that they have read and understood this Integrity &

Compliance module of the USRAP Overseas Processing Manual. The RSC should send any

requests for access to the RefCoord and Program Officer.

RSC management and employees are not permitted to communicate with RSC headquarters

representatives regarding refugee case applicants and information, where this is not part of

routine USRAP processing and where there is no clear need to know, unless previously

approved by PRM/A. Requests for information from RSC headquarters which fall outside

normal USRAP processing steps should always be reported to the RefCoord, even if they do

not specifically violate USRAP data sharing and communication requirements as set forth in

Section 3.0.

Further questions on access by the parent organization of the RSC should be directed to the

RefCoord and Program Officer.

2.2.2.5 Foreign Government Authorities

RSCs may release to foreign government authorities only such information in applicant

records as necessary to facilitate movement of applicants and SIV holders (e.g., to obtain exit

permits). RSCs should generally limit this information to the names, ages, family

relationships, medical condition (when relevant), dates of arrival and departure, transportation

arrangements, and similar information concerning the applicants involved. When permitted

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by formal written arrangements between the United States and other governments and/or

necessary to finalize departure permission, the RSC may release additional case information

to those governments after requesting and receiving prior written approval from PRM/A.

Requests for information from foreign governments which fall outside normal USRAP

processing steps should be reported to the RefCoord. The RSC should use discretion to

determine if a request falls outside normal USRAP processing and consult with the RefCoord

if it does.

2.2.2.6 The International Committee of the Red Cross or the

American Red Cross (ICRC)

RSCs and the RPC may reveal information in an applicant’s record to the International

Committee of the Red Cross (ICRC) or the American Red Cross to the extent necessary to

assist with international tracing efforts for the purpose of family reunification, if the applicant

has signed an authorization specifically for this purpose. Consult the RefCoord for

information-sharing requests to facilitate an ICRC Travel Document.

RSC management and employees are permitted to communicate with ICRC regarding refugee

case applicants and information where such communication is part of routine USRAP

processing and on a need to know basis. Requests for information from ICRC which fall

outside normal USRAP processing steps should be reported to the RefCoord, even if they do

not specifically violate USRAP guidelines.

2.2.2.7 Mental Health and Other Counseling Organizations

Information from applicant records may be released to government or private mental health

counseling organizations or entities as needed to the extent necessary if the applicant poses a

temporary danger to themselves or others. In addition, information from applicant records

may be released to these mental health counseling organizations, in consultation with

PRM/A, to the extent necessary to permit them to assist in making recommendations on the

suitability (or continued suitability) of placements for children under parental supervision.

The RSC should use discretion to determine if a request falls outside normal USRAP

processing and consult with the RefCoord if it does.

2.2.2.8 Members of U.S. Congress

RSC management and employees are permitted to communicate with Members of the U.S.

Congress and Congressional staff regarding specific refugee case applicants and information

pertinent to that Member’s district. RSCs should always include the RefCoord, Program

Officer, and PRM Congressional Liaison on communications with Members of Congress.

Written inquiries (including e-mail) for case status information or other case-specific refugee

information from Members of Congress or their staff that do not specifically relate to

adjudication decisions by DHS should be answered with only the information necessary to

answer the inquiry. Members of Congress or their staff should not pass such information to

persons outside of Congress, except to the refugee themselves or to an individual the refugee

has authorized to receive such information by signing Form G-28, G-28I, or a third party

authorization form. Information in response to telephonic requests from Members of

Congress or their staff may not be provided. No copies of documents or other items from a

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case file may be provided. Information provided on USRAP refugee resettlement cases and

FTJ-R cases must include the reminder:

“The following information is provided in response to the inquiry, however, due to the need

to protect privacy, the information is provided for the sole purpose of responding to the

inquiry and should not be publicly disclosed except to inform your constituent about this

case.”

For SIV inquiries only, information provided must include a reminder that, pursuant to

Section 222(f) of the INA (8 U.S.C. 1202(f)), such information:

1. is to be treated as confidential,

2. is being provided to them solely for purposes related to “the formulation, amendment,

administration, or enforcement of the immigration, nationality, and other laws of the

United States,”

3. should not be shared with other Members of Congress or their staffs except as

specifically needed for the aforementioned purposes, and

4. should not be released to the public.

If the Congressional letter requests that a response be sent directly to a constituent or other

third party, the requested information will be provided to the Member of Congress or staff

member with an explanation that in accordance with law and policies governing the privacy

or confidentiality of Department of State refugee processing records, the Department cannot

provide case status information or other case-specific refugee information directly to the

constituent, unless the constituent is the refugee applicant themselves or an authorized third

party. In either of the latter cases, the applicant or authorized third party would be able to

obtain case status information by inquiring directly to PRM/A or the RSC handling the case.

See Section 2.2.2.8 for additional details on responding to Congressional letters.

2.2.2.9 U.S. Government Law Enforcement Entities

Written inquiries (including e-mail) for case status information or other case-specific refugee

information from U.S. government law enforcement entities that do not specifically relate to

adjudication decisions by DHS, will generally be answered by PRM with the requested

information when such law enforcement entities can demonstrate a specific need to know.

Questions on such inquiries, as well as any inquiries from U.S. state and U.S. local law

enforcement agencies, should be referred to PRM/A for response.

Information in response to telephonic requests from U.S. government law enforcement

entities may not be provided. Responses must be coordinated with and sent from PRM/A in

Washington, with involvement of the Department of State’s Office of the Legal Adviser.

RSCs may not respond to any such law enforcement inquiries from U.S. federal, state, or

local agencies, directly. RSC should forward the request to their RefCoord and Program

Officer.

2.2.2.10 Non-USRAP Non-Governmental Organizations (NGOs)

RSC management and employees are not permitted to communicate with non-USRAP NGOs

regarding refugee case applicants and information, unless previously approved in writing, by

the RefCoord and/or Program Officer. Only NGOs authorized by PRM to provide refugee

resettlement referrals into the USRAP are permitted to communicate with RSCs regarding

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specific refugee case applicants and information where this is part of routine USRAP

processing and on a need to know basis. Requests for information from NGOs which fall

outside normal USRAP processing steps should always be reported to the RefCoord, even if

they do not specifically violate USRAP guidelines. In instances where an NGO is assisting

the applicant, a Third Party Authorization Form must be on file for the specific NGO staff

member assisting the applicant (see Section 2.2.2.1.2.).

2.2.2.11 Media

RSCs are not permitted to speak with the media concerning any aspect of the USRAP without

prior Program Officer approval. RSCs must relay and discuss any media inquiries with

PRM/A, and follow any guidance provided by PRM/A.

Should media inquiries arrive for or about specific refugee applicants, RSCs are never

permitted to provide any refugee data to any media organization in response. RSCs are also

forbidden from assisting members of the media in finding individual refugee applicants of

any specific population or group, however defined. They are only permitted to pass on

inquiries for a specific, named refugee applicant to the refugee applicant and note that they

may engage with the media independently if they wish, but the RSC should have no further

role in that communication. The RSC is not allowed to speak to the media on behalf of the

refugee. Once the message has been delivered to a refugee applicant, RSCs are permitted

only to tell members of the media inquiring on a refugee case that their message has been

passed. PRM/A should be notified but does not need to approve of passing messages from the

media to refugee(s).

2.2.2.12 Research

PRM understands that sharing refugee records, data, and information with research partners

may further the interests of developing better refugee resettlement programs. Accordingly,

refugee records, data, and information may be shared with research partners only with prior

approval from PRM and on a case-by-case basis, in accordance with these guidelines.

General Principles Governing the Sharing of Refugee Records, Data, and Information

for Research Purposes

1. The sharing of government records, data, and information on refugees for research

purposes is not an activity provided for in PRM’s cooperative agreements with RSCs

or its MOU with IOM, nor is it otherwise performed in the ordinary course of

business. Therefore, refugee data originating from WRAPS may not be shared with

research partners without the prior written consent of PRM/A.

2. PRM owns all data maintained in WRAPS, except for information and records in

WRAPS originating from and owned by another U.S. government agency, such as

DHS. Ownership of this data cannot be changed through de-identification of WRAPS

data or transfer of the data into another database. Any MOU or data use agreement that

an RSC or IOM enters into with a research partner must accurately reflect PRM’s

ownership of WRAPS data.

3. The Department of State has the sole authority to publish research based on refugee

records, data, and information gathered before a refugee’s admission to the United

States. RSCs and USRAP-affiliated IOM staff are not permitted to share refugee

records, data, or information collected before a refugee’s admission with research

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partners for the purpose of publication, as publication by an RSC, IOM, or research

partner does not relate to the “formulation, amendment, administration, or

enforcement” of the laws of the United States.

4. Refugee records, data, and information collected by PRM, an RSC, IOM, or another

implementing partner after a refugee’s admission to the United States are still subject

to the confidentiality provisions of PRM’s cooperative agreements and MOU with

RSCs, and IOM.

5. RSCs, USRAP-affiliated IOM staff, and their research partners may publish

aggregated statistical summaries describing the effectiveness of program innovations

that are based on data collected after a refugee’s admission to the United States, as

long as these reports only disclose WRAPS data that is publicly available and do not

allow individual refugees and their resettlement locations to be identified.

Process for Sharing Refugee Records, Data, and Information for Research Purposes

PRM recognizes that RSCs, and IOM have a strong interest in partnering with researchers in

order to improve their methods of implementing and evaluating the USRAP. For researchers

seeking general information, it is permitted to share public websites and/or resources, such as

CORENav.org or PRM’s website. Before sharing any non-public refugee records, data, or

information with a research partner, RSCs and USRAP-affiliated IOM staff must follow this

process:

1. RSCs and IOM must submit a data sharing proposal to PRM and obtain PRM’s written

approval on a case-by-case basis before sharing WRAPS data with another person or

entity for research purposes. Data sharing proposals must include the following

information:

2. Description of the type and scope of WRAPS data to be shared.

3. Name of the intended research partner.

4. Explanation of how the sharing of WRAPS data will further the implementation of the

USRAP.

5. Draft of the data use agreement to be signed by the intended research partner.

6. PRM will review the data sharing proposal in consultation with the Department of

State’s Office of the Legal Adviser to verify whether the proposal is consistent with

the Department’s privacy policies and guidelines and will issue a written response

approving, denying, or requesting modifications to the data sharing proposal. PRM

will strive to provide a written response within 30 days of receiving the data sharing

proposal.

7. Upon receiving written approval from PRM to proceed with a data sharing proposal,

the RSC, or IOM must sign a data use agreement and non-disclosure agreement with

the intended research partner that specifically prohibits any disclosure of individual

level data and directs the research partner to destroy all shared data after completing

the approved project.

8. The RSC, or IOM must send PRM by email a scanned copy of the data use agreement

signed with the research partner within 5 business days of the date of signing.

9. Upon following the steps described above, the RSC, or IOM may securely share an

appropriately de-identified dataset with research partners. To appropriately de-identify

data, PRM requires the removal of personally identifiable information (PII), including

names, dates of birth, addresses, contact information, personal health and medical

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information, biometric records, full-face photographic images, alien numbers, social

security numbers, and other identification numbers. The data must be hosted on a

secure server that is approved to handle sensitive data, and any refugee records, data,

or information shared via e-mail must be encrypted.

3.0 Data Sharing and Communication in the USRAP

The governing principle of these guidelines is that information about applicants and approved refugees

can generally be disclosed only as specifically necessary to process the individual’s application or Special

Immigrant Visa for admission to the United States. The disclosure of information should contain the least

amount of PII possible to complete official duties.

RSCs must record in the contact log in WRAPS any interaction with an applicant or individual for whom

the PA has signed a Third Party Authorization Form. RSC should record contact with unauthorized

individuals who tried to seek information about the applicant from the RSC as well. Such interactions

must be conducted using RSC phone and/or email addresses. The RSC does not need to enter routine

contacts for processing steps (e.g., the prescreen interview, routine transactions with UNHCR, or regular

scheduling with IOM Ops and MHD for the purposes of processing cases) in the contact log.

The record in WRAPS of any authorized disclosure must include the date, nature, purpose of the

disclosure, written authorization from PRM if applicable, and the name and address of the person or

agency to whom the disclosure was made. Best practice includes attaching the correspondence with third

parties in WRAPS as well.

All USRAP communications should provide efficient and responsive information to the U.S.

Government, USRAP processing partners overseas, domestic resettlement partners, and applicants, while

protecting data and information under all applicable privacy laws and regulations.

Communications in any form should be professional and clear. It is expressly forbidden to be rude,

demeaning, degrading, harassing, threatening, discriminatory, overly familiar, or send inappropriate

materials in conjunction with any USRAP communications.

The guidelines below do not cover every possible scenario for communications regarding a USRAP case.

When in doubt, RSCs and other USRAP partners should contact their Program Officer for further

guidance.

3.1 Receiving, Sending, and Disclosing Applicant Data

3.1.1 Tableau Reports and START Filters (For RSCs Using START)

Access to Tableau should be limited to RSC management, staff who are responsible for RSC

reporting, and staff who have a case processing need. The RPC and RSC reporting staff are

responsible for monitoring the data provided in reports as well as access to use of reports and

Tableau.

Data provided must be on a need-to-know basis to perform a case processing function. PII must

be limited to the greatest extent possible. Reports created in Tableau must be audited quarterly to

ensure that PII is included on a need-to-know basis only, is a must-have in the report, and is

overall limited to the greatest extent possible. The audit must also ensure that data in reports is

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not excessive and is appropriate for user permissions. Results of quarterly audit should be

submitted to RPC Reporting Team.

Sharing of Tableau reports is permitted within the guidelines set forth in this document. Follow

guidelines in Section 2.0 on sharing records and Section 3.1.1 on protecting data when sharing

reports.

Note for RSCs using START: START users currently have the ability to export START filtered

lists as a reporting feature; however, this capability should not be used without authorization from

the RPC. In general, if system data needs to be viewed or shared outside of the START system, it

should be managed through Tableau reports. START filtered lists should not be exported even

though the functionality exists. Tableau reports have gone through an extensive approval

process, and by limiting report creation to Tableau, the USRAP program can enforce its

commitment to data integrity and reduce the distribution of PII outside of system when it is not

necessary. If staff have a justified business need to export data that cannot be met through

Tableau reports but can be met by exporting START filtered lists, an exception may be pursued

by submitting a request for RSC Reporting Team and RPC approval. Additional instructions on

this process will be provided to the RSC once it transitions to START.

In order to enforce the prohibited use of exporting START filtered lists, RSC Compliance/IT or

similar staff must conduct monitoring/spot checks on staff computers and emails to ensure that

START filters containing applicant PII have not been downloaded/ circulated unless explicitly

authorized by the RSC Reporting Team and RPC.

Following the deployment of START, RSCs must log in their GitHub Repository a business case

with a justification for each report created in Tableau and with justification for any PII included

in Tableau reports.

3.1.2 RSharenet

Files containing PII that are uploaded to Rsharenet must only be accessed and used by staff who

have a case processing need or need to know.

3.1.3 Email/Written Communication

The use of personal email is strictly prohibited for receiving, sending, and disclosing applicant

data. Additionally, it is prohibited to forward or enable all messages to be automatically

forwarded to an address outside of WRAPS or RSC systems. Taking screenshots or photographs

of data is strictly prohibited. Should any staff find evidence that any RSC staff has photographed

or taken screenshots of data and transmitted those images to personal email or devices, the RSC

must notify the RSC Director or Deputy immediately for review. RSC Compliance/IT or similar

staff should conduct random monitoring/spot checks of user devices and email accounts to

identify if data has been exported (from START), photographed, screenshot and forwarded to

personal email or devices. Use organizational specific email addresses when interacting with

external partners or applicants regarding case information. Whenever possible, group email boxes

should be used for communications on USRAP cases. This provides oversight and history into

what has been communicated and protects RSC and USRAP partner staff from suspicion of

malfeasance.

Use approved email templates, where available, when corresponding with external partners or

applicants. Emails and letters should clearly identify the sender, the recipient, and the purpose of

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the communication. Use proper care to verify that email recipient addresses are accurate, in order

to avoid sending sensitive information to the wrong sender. This is especially important for email

sent to non @wrapsnet.org, non @uscis.dhs.gov, and non @state.gov email addresses or to many

recipients.

Emails and written communications can be written in any language, but RSCs should always

include accurate and complete English translations in addition to the original language for any

official USRAP communications that are scanned into WRAPS. For internal RSC emails, an

English translation is not required, though RSCs should ensure they have proper oversight over

internal communications through their own regulations and management structure.

When corresponding with USRAP partners and authorized third parties, PII and SPII should

never be included in the email subject. Sensitive PII (SPII) should only be included in the body of

the email if the email is encrypted using an email software encryption feature. SPII should

otherwise be attached to the email with encryption (see Section 3.2). If SPII was included in the

original message, insert “XXXX” in place of the SPII when responding. Per Section 3.2, notify

RSC Director/Deputy when partners commit such breaches.

When corresponding with applicants, it may not be practical or feasible to send SPII as an

encrypted file attachment. Therefore, the RSC should strive to minimize the use of PII in the

email (e.g. ‘Dear Applicant,’). If the RSC is responding to an applicant who provided SPII in

their email, the RSC should place an “XXXX” in place of the SPII when responding. Although

PII does not strictly require this type of redaction, all PII should be minimized when sent via

email, including to USRAP partners, applicants, and internal RSC colleagues.

RSCs can include non-PII in email/written communications, including:

Signatures with contact information

Notices regarding how, when, how-not-to communicate

Privacy regulations and warnings

Customary greetings

Customary signatures/end-of-letter salutations

General information regarding refugee resettlement processing

RSCs should ensure non-PII included in an email or written communication is standardized using

the RSC Inquiry Response Template. If it is included in one refugee case status update, it should

be included in all refugee case status updates. Similarly, information sent to USRAP partners

should be standardized across different partners, as appropriate. These guidelines also cover web-

based communications through secure interfaces with applicants or other USRAP partners.

See Section 3.0 for information on routine correspondence between RSC and other agencies.

3.1.3.1 Short Message Service (SMS) and Other Communication

Platforms

RSCs may communicate the following to refugee applicants via SMS on an RSC-issued

phone or via other RPC-approved messaging services on RSC-issued devices:

anti-fraud warnings,

information on holidays and office closures,

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general resettlement information,

links to additional online resources,

scheduling USRAP events, including appointment date, time, and location.

Approved messaging services to use when communicating with applicants refer to those that

have been explicitly approved by the RPC Security Team for use on RSC-issued devices

(personal devices cannot be used). All requests to use a messaging service to communicate

with applicants must be forwarded to the RPC Security Team for approval prior to use.

Bulk SMS communications that are sent to all applicants do not need to be updated in the

Contact Log. However, case or applicant specific information sent via SMS must be updated

in the case’s Contact Log.

Refugee PII or other sensitive data can only be communicated via RSC email except in

extreme circumstances in which an applicant does not have access to email. RSCs may accept

(i.e. receive) PII from applicants over text or other messaging service by exception –

permission to receive PII documents or PII in text must be granted by the RSC Director or

Deputy Director after presenting a justification for why email, mail, or in person transmission

is not possible. The exception, including the rationale and approval, should be documented in

the WRAPS contact log along with the general message contents. Although receiving PII in

extreme circumstance is permitted by exception, RSCs should never send PII or official case

processing documents (e.g. denial letter) over SMS or another communication platform other

than an RSC email account.

RSCs should encourage applicants to set up a free email account, if possible, during data

collection or prescreen so that documents can be transmitted over an official email channel.

3.1.4 Telephone/In-Person

RSCs should maintain management oversight over telephonic and in-person communications

with USRAP partners and refugee applicants.

Telephonic/in-person communications with refugee applicants should take place in RSC

workspaces, using RPC-approved messaging services on RSC equipment, and must be logged in

WRAPS. For RSC workers conducting circuit rides, telephonic/in-person communications with

refugee applicants should only take place in designated RSC workspace areas. This guidance also

applies to individuals authorized to work from home—such individuals may communicate with

applicants using RPC-approved messaging/communication services on an RSC-issued phone or

while logged into WRAPS via an RSC-issued computer using a VPN.

Telephonic inquiries by refugee applicants, telephonic case counseling, and in-person case

counseling are allowed for:

Scheduling prescreen interviews, case status consultations, USCIS interviews, medical

examinations, or other USRAP processing functions.

Responding to applicant inquiries by phone with case status updates.

The RSC is not required to offer telephonic or in-person case counseling. The RSC should

minimize the transmission of PII and protect refugee case statuses from unauthorized disclosure

when providing telephonic or in-person responses to inquiries.

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Please note that telephonic or in-person inquiries or case status counseling is not authorized for

third parties, even if they have a signed authorization.

Refugee applicants must not be contacted using an RSC employee’s personal cell or personal

landline phone, in any circumstance. If an RSC employee is contacted outside work by a refugee

applicant, they should re-direct the applicant to the appropriate RSC phone or email address, and

not provide any further information. RSC employees must report the contact to their RSC

management as soon as possible.

RSC employees may not fraternize with refugee applicants. RSC staff should not be penalized for

simple contact (regular greetings) with refugee applicants if it is reported appropriately.

3.1.5 Communication with Applicants

RSC staff tasked with refugee communication must not take any unsolicited calls, emails, or

visits from applicants except during “open” hours or walk in hours. All visits or conversations

outside of a normal interview or outside of RSC office hours must have the occurrence and

substance of the conversation recorded in the “Contact Log” in WRAPS. Instances of other

unsolicited interactions (including calls or emails outside of official means) must immediately be

reported in writing to supervisors or the RSC fraud email. Staff not tasked with refugee

communication must also report unsolicited interactions to a supervisor or the RSC fraud email

address immediately.

All case-specific information should be made available to refugees by email, secure website (if

available), mail, in person and/or by phone. All refugee documents should be provided on RSC

letterhead to demonstrate authenticity.

RSC staff should not maintain friendships or relationships with applicants, including on social

media, nor should they communicate outside of official means or business hours. If such

relationships are unavoidable, staff and applicants must disclose their relationship. See Section

4.1.3 on how to document the relationship. Any attempts by an applicant to develop a relationship

beyond a professional relationship must be reported to a supervisor.

All written and, when appropriate, verbal communication must emphasize the USRAP is free of

charge, while providing details on how to report fraudulent activity. This information should

appear in all RSC staff email signatures as well. RSCs must display informational posters in

visible locations in target languages(s) in processing locations. Posters should be developed with

consideration for illiterate populations, communicating that the USRAP is free of charge,

including details on what fraud is and how to report any fraudulent activity. Include information

that any reports to the RSC are confidential. Applicants must be made aware of fraud risks and

reporting abilities. Applicants should be told during prescreening what official correspondences

from the RSC look like.

Only RSC email and RPC-approved messaging services are permitted for sending digital

messages to applicants. If an RSC-issued phone/tablet is used to communicate with an applicant,

either RSC email or an RPC-approved app must be used to do so. RSCs may contact the RPC

with any apps that they would like to have approved for applicant communication, and the RPC

will issue a decision.

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3.1.5.1 Informing Applicants of USRAP Data Sharing

RSCs must provide each refugee applicant 14 or above (not including SIV holders) with the

Notice on Confidentiality of Personal Information form, printed on standard RSC letterhead

or on blank paper, at the time of the prescreening interview, or the first meeting with an RSC

staff member. This form informs the applicant it may be necessary to release the information

they supply, or the information the U.S. government or RSC gathers about them in

connection with the application in whole or in part.

Note: The SIV holder is informed of data sharing through the Refugee Benefits Election

Form.

Each applicant aged 14 or above is required to sign the Notice on Confidentiality of Personal

Information, acknowledging understanding and acceptance of the terms for release of

personal information. RSCs may have 13 year old applicants sign if the applicant is likely to

travel after turning 14 years old. RSC staff must inform all applicants of the purpose of the

document before the applicant signs the document. If applicant ages into 14 years and

previously did not sign the form, the applicant can still travel, however, RSC should make

every effort to ensure the applicant has received and read the form prior to his/her travel, such

as during a Travel Fingerprint appointment.

If an applicant is unable to sign, a family member on the same case may sign for the applicant

and mark their name and of whom they are signing on behalf. If no family member on the

case is able to sign, the forms should be explained to the applicant in full so they understand

the content, and a family member not on the same case may be allowed to sign for them,

following indications that the principal applicant has understood. Applicants are permitted to

make a mark to indicate their signature if they are able. If they are not able, and no family

member on or off the case is available to sign, the RSC caseworkers should indicate that the

form was explained, and note the reason the applicant is not able to sign.

If an applicant can sign the form, but refuses, the RSC should note the reason for the refusal,

and contact the RefCoord or Program Officer for further guidance.

3.1.5.2 Releasing Documents to Applicants

The RSC may release a copy of documents to an applicant only if that applicant provided the

document (e.g., marriage certificate, death certificate, divorce certificate). If the RSC releases

a copy to the applicant, the RSC shall maintain a copy in the applicant’s record.

Except as permitted above, RSCs should advise any individual requesting copies of

documents in applicant records under FOIA or the Privacy Act to submit the request to:

Director, Office of Information Programs and Services

U.S. Department of State, A/GIS/IPS/RL, SA-2

Suite 8100, Washington, D.C. 20522-0208

Fax: (202) 261-8579

FOIA requests also may be submitted electronically. Individuals requesting their own

personal records under the Privacy Act must provide an original signature and may not

submit electronic requests.

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3.1.5.3 Case Status Inquiries

RSCs should use the RSC Inquiry Response Template in response to case status inquiries

from an authorized third party. Alternatively, RSCs can select the appropriate answer from

the form and place it in the body of an email response or use the form and delete all options

except for the relevant case status. The form may be customized with the RSC’s logo (in

accordance with the RSC Style Guidelines) and/or contact information, personalized

greetings, local procedural information, and other personalized language, and additional case

statuses may only be added with advance permission from PRM/A.

The RSC Inquiry Response Template is not intended to be used for responses to

Congressional inquiries. RSCs should respond to Congressional inquiries in the manner in

which they are received. Formal letters signed by the representative should be responded to

with a letter signed by the RSC Director or his/her designee. Email inquiries from

Congressional staff can be responded to via email. Records of Congressional inquiries and

responses must be scanned and attached in WRAPS.

3.2 Protecting Data

3.2.1 Protecting Media

Local administration personnel at RSC locations are not authorized to sanitize SBU media for re-

use as non-sensitive unclassified media. Therefore, any hard drive or non-volatile memory

(secondary storage or long-term persistent storage) that, at one time, contained WRAPS data must

be shipped by RSC local administration personnel through their RefCoord to the RPC via

diplomatic pouch for destruction and disposal as unclassified refuse. This includes for computers,

laptops, printers, copiers, etc. if they contain a hard drive or memory that stored WRAPS data.

RSC-issued phones are not included in this policy as they are not authorized to store WRAPS

data. WRAPS data refers to data specific to refugee applicants that is stored in WRAPS as

defined in the WRAPS Rules of Behavior.

The RSC should contact their RefCoord to arrange for the item to be shipped via diplomatic

pouch. Note that any volatile storage (RAM) will be destroyed once the system is shut down. All

hard drives and non-volatile memory should be sent directly via diplomatic pouch to the

following address:

ATTN: RPC Director or Deputy Director 2201 C STREET, NW

SA-9, PRM/A

Washington DC 20522

Any hard drive or non-volatile memory cannot, for any reason, be sanitized or repurposed by the

RSC.

3.3 Data Breaches

USRAP staff ensure data integrity by following the safeguarding PII practices policy outlined in

Section 3.1 and Section 3.2. However, a breach of PII can occur. A data breach is defined as a loss of

control, compromise, unauthorized disclosure, unauthorized acquisition, unauthorized access, or any

similar term referring to situations in which persons other than RSC and RPC staff and external

partners, for an other than authorized purpose, have access or potential access to PII (whether

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electronic or hard copy). If a breach has occurred, it is the RSC staff’s responsibility to follow the

below policy.

RSC employees must report any breaches in physical or electronic file security or suspected PII data

loss immediately, and no later than four hours, to the RSC Director (or other senior manager if the

Director is not available), who will notify the RefCoord, the Program Officer, RPC Security Team,

and the RPC Director.

3.4 Handling of Records

3.4.1 Maintenance of Records

The RSC must maintain applicant records under administrative control as specified below. These

standards are the minimum authorized. If an RSC is not able to comply with these standards, the

RSC should notify the RefCoord and PRM/A for further guidance.

The RSC must designate a file library and use a file-tracking database to check files in and out to

specific staff. All files and documents containing personal information of refugees must be

secured in the file library or in a locked filing cabinet overnight and when not in use. Access to

physical files should be restricted to those employees who have a demonstrated need in their

work. Physical files should be maintained in locked containers or restricted access file rooms in a

secure facility at all times when not in use and should always be secured in a locked container at

the end of the day. File rooms should be secured using an access code or card-lock system with

different permission levels. A list of staff with the access code/card access shall be maintained by

management. The code must be changed upon the departure or termination of any employee on

the list. The RSC must audit the physical files two times per year. Transporting applicant

data/files outside of the office is strictly prohibited unless authorized by the RSC Management for

his or her work stream. Develop and follow SOPs to transport files that account for local security

considerations. The SOPs should be reviewed and approved by the RefCoord and Program

Officer.

When on circuit rides, the RSC staff member responsible for file security must ensure files are

stored overnight in a secure, locked area accessible only to designated RSC staff. If possible,

files should be locked in a container (e.g. trunk) in a secure room.

In many cases, hand-carrying is preferable to shipping physical files. If shipped or transported on

a flight, physical files should be placed in secure containers and sealed appropriately and as

securely as feasible. Any breaks in the integrity of the shipping container or files should be

reported as soon as discovered. RSCs must check with their RefCoord to ensure companies used

to ship physical files are deemed acceptable by the U.S. Embassy or Consulate.

The RSC is allowed to travel with refugee case files as checked baggage on a flight if the RSC

has received assurance from the airline that the files will remain secured and untampered with

during the entire journey. Therefore, the RSC should work closely with airline and airport staff to

ensure that appropriate security controls can be conducted without exposing sensitive information

or PII. The RSC should ensure the security and integrity of the physical files is guaranteed by the

airline and airport staff throughout the journey.

Routine file shipping (e.g. sending files to the FOD for wet stamping) does not require PRM

approval. However, the RSC should seek RefCoord or Program Officer approval for non-routine

shipping of USRAP applicant data. See Section 3.4.2 on disposition of records per DOS policy.

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For the P2 I-130 Program at the RPC, Expression of Interest Packets are generated from the

USRAP case management system and sent directly to the petitioner via USPS. The envelopes

must be addressed directly to the petitioner if sent via physical mail. Alternatively, these packets

may be emailed to the petitioner or a representative who has provided a signed and completed G-

28 at the email address on file.

Files that are damaged or marked for destruction should be destroyed under approved PRM

destruction methods and not left in normal garbage. See below on disposition of records.

Hardcopies of records and reports should be destroyed accordingly once they are no longer

needed by the RSC. The electronic copy of records and reports that have no further administrative

value may be destroyed or deleted within 180 days after the copy was produced.

Any files left unsecured (i.e., loss of control, not in a designated locked cabinet/drawer) outside

of RSC workspaces should be reported, under the reporting procedures for breaches in PII. See

Section 3.3 for more information on reporting procedures.

3.4.2 Retention and Disposition of Records

The RSC must preserve active case files in a manner that will prevent deterioration of these

records until such time as the applicants are Stateside or denied or the case is closed. See Section

3.4.1 on maintaining a file library. RSCs must then comply with published Department of State

record disposition schedules. Chapters 12 and 25 of the Department of State Records Schedule

describe refugee records and give disposition schedules and authorities. Note: Chapter 25 applies

to PRM staff, not RSCs.

In the event the files are forwarded to an Embassy or the National Records Center (NRC), they

should be forwarded intact and as designated by PRM/A and/or USCIS.

If an RSC needs advice regarding records management or procedures for destroying or retiring

records under the Department of State disposition schedules, or if an RSC is unable to comply

with records requirements, the RSC should contact the RefCoord and Program Officer.

The RPC maintains electronic records of all WRAPS data in case of disaster or accidental

destruction. The RPC will maintain WRAPS records for five years following the individual’s

arrival in the United States and/or the last action is taken on a case before archiving records. The

RSC should contact the RPC and/or PRM should they need to make updates or inquire about

cases that have been archived or otherwise disposed.

The RSC should have in place a contingency plan for safely storing/relocating hard files in the

event of a disaster.

4.0 Integrity and Compliance

4.1 Roles and Responsibilities

4.1.1 RSC

The State Department has a zero-tolerance policy for fraud in the USRAP. Fraud is generally

defined as any intentional deception or misrepresentation used to benefit oneself or someone else.

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Malfeasance is generally defined as intentional conduct that is wrongful or unlawful, especially

by officials or public employees, or in this context RSC and other USRAP partner employees.

This document addresses the key roles and responsibilities of RSCs in ensuring the integrity of

the program and guarding against internal malfeasance in the processing of refugees for

resettlement. The following highlights the main PRM-mandated safeguards and responsibilities

RSCs must implement. This summary is not exhaustive, however, RSCs are still required to read

this document in its entirety, comply with all regulations therein, and report on their compliance

annually.

Annual RSC Compliance Report: RSCs must report to PRM on their compliance with all

required RSC program integrity measures through the updated FY21 Integrity & Compliance

Matrix. Compliance matrices are to be submitted by RSCs annually on October 15 for the

previous fiscal year.

Approved adaptations of the guidelines for small sub-offices and satellite offices should be

reported in the annual Compliance Matrix report along with measures taken to implement the

intent of the guideline.

RSC management must establish and maintain a fraud complaints email inbox and a locked

physical box for paper complaints allowing for anonymous tips and must have a whistleblower

protection policy in effect. The email and physical fraud boxes should only be checked by RSC

senior management or dedicated compliance officers (except for translation services) and should

be checked no less than once per day, if possible. Both RSC staff and applicants/non-RSC staff

can use either of these systems to submit a fraud complaint. Senior management/compliance

officers should be trained on how to handle such reports and the headquarters organization should

have an established investigations mechanism in place. RSC agency headquarters are to conduct

annual monitoring that includes fraud vulnerabilities, and submit results to PRM; and ensure

performance review mechanisms adequately evaluate workplace conduct. Compliance officer

should report complaints directly to RSC senior management. In small sub-office locations with

only one or two staff members, the RSC should utilize the larger NGO or IOM country office

infrastructure, if available. The head of office or non-USRAP manager in the country office

should check the physical fraud box and report any allegations to RSC sub-office management, or

to senior management in the main office of the RSC if the allegation is about sub-office

management.

RSCs must create and maintain a Fraud and Ethics Committee of general staff and management

(particularly those who best understand the applicants). The Fraud and Ethics Committee, in

coordination with RSC management, should conduct annual staff fraud risk assessments focusing

on the impact and likelihood of fraud and staff malfeasance, examine the suitability of existing

staff fraud controls, and revise the controls as appropriate. Fraud risk assessments and mitigation

steps should be annually reviewed with the RefCoord, Program Officer, and relevant RPC staff to

jointly examine the suitability of existing staff fraud controls and revise controls as appropriate.

The RSC Director or their designated representative and the Refugee Coordinator should meet

annually with the U.S. Embassy Regional Security Office (RSO) and Consular Section to share

information on local fraud trends and methods, including information on possible attempts to

infiltrate the USRAP. The RSC and RefCoord should establish quarterly fraud trend meetings

with UNHCR, other governments, and other relevant stakeholders in the primary processing

location as well as two to four other locations with significant resettlement activities, if

applicable.

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4.1.2 Procedures for Responding to Allegations of Fraud or

Malfeasance

RSC staff must report any observed or alleged instances of fraud or malfeasance, whether internal

or external, immediately to the Director. Within 24 hours of receiving the fraud allegation

information, the RSC is required to inform the RefCoord, Program Officer, and RPC Director.

Notification should be made even if RSC is still gathering information on the malfeasance.

The RSC must also directly inform the State Department Office of the Inspector General (OIG)

after informing PRM/A. Program Officers will also notify OIG as part of the memo to PRM

leadership. For RSC activities being performed in accordance with cooperative agreements

awarded by PRM, this reporting shall be consistent with 2 CFR §200.113 per the Department of

State Standard Terms and Conditions. For RSCs operating under contribution agreements

pursuant to the Memorandum of Understanding between IOM and PRM, IOM shall fulfill the

intention to inform the U.S. Department of State of allegations of fraud or malfeasance where

feasible by also reporting separately to the OIG, in accordance with the OIG’s standards and

instructions, in addition to reporting to PRM. Disclosures to the OIG should be sent through the

OIG website.

Any staff member under investigation due to a suspected breach of confidentiality, commitment

of fraud, or commitment of malfeasance should be suspended immediately if any positive

findings result from investigation of the incident. If a staff member is under investigation for a

serious incident (that does not rise to the level of breach of confidentiality, commitment of fraud,

or commitment of malfeasance), it may be appropriate to suspend the staff member for the

duration of the investigation. The RSC should consult with their Program Officer for further

guidance.

The RSC Director or Deputy, or Headquarters if management is implicated in the allegation, must

ensure proper reporting of any fraud or internal malfeasance. This should be done in consultation

with the RefCoord and the Program Officer, resulting in a written report and appropriate

organization-specific disciplinary measures (as well as additional security enhancements

identified by the RPC for specific incidents), which should be shared with PRM.

4.2 Guidelines for Staff, Interpreters, and Workspaces

4.2.1 Staff Screening (international/national full- and part-time RSC

employees)

The RSC must have a reputable entity complete background checks for international staff prior to

hiring (and retroactively for all currently employed international staff). These checks should

produce RSC-specific risk assessments, and the level/detail of the background check should align

with vulnerabilities identified by RSC management in the RSC-specific risk assessment. The

level of background check should be agreed with PRM/A in advance. In addition, RSCs must

ensure none of their staff are prohibited from receiving federal awards, including making sure

they have no exclusion records listed on www.sam.gov. Note: This includes all staff, whether

local or international hires. International staff background checks must be renewed every five

years.

Prior to hiring, national staff require a local police certificate issued within the last two years (and

retroactively for all currently employed national staff) certifying a clear record. The police

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certificate should be renewed and documented every two years, where possible. In certain

contexts, PRM may ask RSCs to work with the RefCoord and RSO to determine if the Embassy

should conduct additional name checks for national staff prior to hiring.

Staff with any family members or acquaintances under USRAP consideration must immediately

report the connection and recuse themselves from any dealings with the case. Staff must sign the

USRAP Affiliation Declaration (UAD)– Staff & Contractors Form ensuring they understand this

policy; similarly, applicants must also sign the UAD – Applicants Form ensuring they understand

this policy (see Section 5.3.16 Additional Forms in the Case Management module). Create the

form using RSC letterhead and keep all signed forms on physical or electronic file with RSC

management.

Refugee applicants with USRAP-affiliated acquaintances, such as individuals working at the

RSC, must report the connection. All applicants must sign a form during the initial Pre-Screen

interview ensuring they understand the policy. This form should be created by the RSC and be on

RSC letterhead. All signed forms must be kept in the applicant’s file.

4.2.2 Translator, Interpreter, and Other Contractor Screening

(contract, not RSC employees)

Translators

The RSC is responsible for facilitating translation. Depending on the language resources

available, this can be done either internally or from a professional translation service.

Contracted Interpreters

Prior to hiring interpreters, RSCs should obtain background checks and reference checks and a

local police certificate issued within the last two years certifying a clear record. The RSC should

document attempts to obtain local police certificates and discuss with the RefCoord and the

Program Officer if the interpreter is unable to obtain the police certificates. The police certificate

should be renewed every two years, where possible. Additionally, based on local government

regulations, it may be necessary for the RSC to have a record of the legal status of a contract

interpreter. Additionally, a contracted interpreter should disclose if they currently have or

previously had a U.S. refugee or asylum application.

In finding possible interpreters, names should be run through www.sam.gov, while using

UNHCR, IOM, or other partners to source and reference potential hires. The RSC must maintain

consolidated information on interpreters to ensure that any who are barred or problematic are not

rehired. All interpreters must read and sign, at a minimum, the local Interpreter Code of Conduct

form.

Interpreters with any family members or acquaintances under USRAP consideration must

immediately report the connection and recuse themselves from any dealings with the case.

Interpreters must sign a form that they understand this policy; similarly, applicants must also sign

a form that they understand this policy (see Section 5.3.16 Additional Forms in the Case

Management module). At the beginning of any new interaction (interview, appointment, etc.) the

RSC staff should check if the assigned interpreter and applicant are acquaintances.

Interpreters should rotate among staff where possible. As a best practice, interpreters for pre-

screening interviews should be assigned daily so interpreters and caseworkers do not know who

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they will be paired with ahead of time. Interpreters must translate documents at the RSC with

RSC staff present. If it is a challenge to identify multiple interpreters for a language, the same

interpreter may be used at all steps for all cases which speak a certain language with RSC

Director or Deputy approval.

Other Contractors

RSC should run other contractors (e.g., drivers, security, childcare, etc.) through www.sam.gov

and conduct reference checks as practical. Police certificates and additional background checks

are not required.

4.2.2.1 Requirements for Interpreters during USCIS Interviews

The following requirements apply to interpreters for USCIS interviews, and not necessarily

RSC prescreening. Interpreters for USCIS interviews must be proficient in English and either

the native language of the applicants or another language in which the applicants and

interpreters are fluent. It is preferable for applicants and interpreters to use the native

language of applicants, as opposed to another language in which the applicants are proficient.

The first priority for hiring an interpreter for USCIS interview is selecting individuals who

have residency or citizenship in the processing location. If the skill set is not available among

residents/citizens, the RSC can hire asylum seekers or refugees. In such situations, the RSC

may hire refugee interpreters for USCIS interviews who have already been approved for

resettlement to the United States, if there are no other options. To use approved USRAP

refugees as interpreters, RSCs must first receive approval from their Program Officer who

will bring the request to the USCIS Desk Officer prior to the circuit ride. If a USCIS Team

Leader discovers that an interpreter is an approved refugee whose interpretations services was

not previously agreed to at the USCIS headquarters level, the Team Leader will alert the

appropriate USCIS Desk Officer immediately so that alternatives can be considered. This

may delay interview of refugee applicants during a circuit ride.

See USCIS Interpreter Guidance for details.

4.2.3 Workspace Compliance

This section details policy regarding the physical locations from which RSC staff can complete

their work and work privately to ensure only appropriate individuals can see work products

and/or participate in work and case-specific conversations.

At Work

Conversations regarding work and/or case information must be limited to private areas (i.e.,

offices, conference rooms, etc.). RSC staff should not discuss work and/or case information

in shared spaces (i.e., lobby, kitchen, etc.). RSC staff must not leave case information

unattended, visible, and/or easily accessible to others. All work and/or case information

should be stored securely and out of sight when not in use.

Open door policy – i.e., as a rule, office doors must be open except as needed for

confidentiality purposes, such as interviews, personnel discussions, etc. See Section 4.1.9

for information on “line-of-sight.”

At Home

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RSC work from home, which involves accessing the USRAP case management system, should be

limited to senior management positions with remote access, as approved by the RSC

Director/Deputy. In rare or extraordinary situations, and as needed to maintain critical processing

activities, PRM/A may approve in writing temporary remote access to the USRAP case

management system for additional RSC staff on a case by case basis.

Staff with permission to work from home should:

Conduct work-based activities on an RSC-issued computer or phone.

Connect to a private network (e.g. home network), rather than a public connection (e.g.,

coffee shop).

Limit conversations regarding work and/or case information to private areas. This includes

communication with refugee applicants on RSC-issued phones.

Staff should ensure that others in the household do not have line-of-sight visibility of work

products or PII or overhear case information.

RSC staff must not have hard-copy case information, or other PII at home. By rare

exception, such information can be taken home with written approval from the RSC

Director and/or Deputy and it must be clear by which date the RSC staff member must

return the information to the office. Further, RSC staff must request permission in writing

from the RSC Director/Deputy prior to printing/scanning PII or sensitive information while

working from home/remotely. If permitted to do so, all documents with PII or sensitive

information must be stored in a secure location that cannot be accessed by anyone else

when not in use and must be returned to the RSC for storing or destruction as soon as

possible.

Computer equipment and remote access devices should be stored in a secure location where

they are not accessible to others.

Equipment must always be protected from potential theft or unauthorized use.

On Official Travel (including Circuit Rides): RSC staff should limit conversations regarding

work and/or case information to designated work areas (i.e., interview rooms, designated RSC

and/or USCIS work areas, UNHCR official work areas, etc.). RSC staff should not discuss work

and/or case information in shared spaces, (i.e., lobby, kitchen, transportation with non-RSC staff,

etc.) or in hotels, restaurants, etc.

While on official travel, RSC staff must not leave case information unattended, visible, and/or

easily accessible to others. At the end of a workday, all work and/or case information should be

stored securely with a USCIS team leader and out of sight when not in use. The RSC must

designate a person responsible for file security during circuit rides (See Section 3.4.1).

4.2.3.1 Control of Access Points

Security company/guards/receptionist must monitor access to the RSC and its grounds.

Access to the RSC and its grounds must be monitored and controlled at all times, including

with regularly monitored CCTV of building access points and common areas, as allowed by

local privacy laws. CCTV should be regularly monitored by a designated staff member and

recorded with stored backup for 90 days. RSC management should review local or

organizational guidelines for information on disposition of CCTV recordings. If the RSC

office operates in an area where local privacy laws prohibit surveillance/CCTV, the RSC

Director should report this in the annual Compliance Matrix.

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Visitors must be escorted in “RSC Only” areas. Access to the “RSC Only” areas must be

controlled. For example, after entering the office, the RSC may have an area for cultural

orientation classes where applicants are not required to be escorted. The RSC must control

access to further areas where staff offices are located and escort visitors in those areas.

Refugees and staff should have separate access points. Refugee access to areas designated for

interviews or cultural orientation should also be limited. Refugee access to the RSC should be

limited to persons with appointments, except during walk-in consultation times.

Prior to entering RSC workspaces (which are defined by locations with access to PII), all

RSC staff, visitors, and refugees must surrender any personal electronic devices which can

take pictures, record, or connect to the internet. RSC staff may keep phones issued by the

organization. Refugees entering RSC facilities should be physically screened for electronics

and items which can be used as weapons. The RSC staff/contractors receiving applicants’

electronics and other items during screening will issue a ticket for the applicants to retrieve

their possessions upon exit. The items will be stored in a safe location accessible only to RSC

staff/contractors/security personnel.

Refugees and interpreters should have separate waiting areas. If there is no dedicated waiting

room available to interpreters, they should be escorted to an area away from refugees while

not engaged in interviews.

For information on securing and maintaining physical files, see Section 3.4.1.

4.2.4 Visual Identification

RSC staff must always wear their identification badges (provided by the RSC) on premises and

while on official RSC business (unless restricted for security reasons). All people (e.g., visitors,

contractors, interpreters, refugees, vendors, etc.) on RSC premises must have adequate

identification that shows their authorized presence or responsibility inside the RSC (i.e., visitors,

contractors, interpreters, refugees, vendors, etc.).

Refugees must be provided with identification to indicate purpose of visit (e.g., cultural

orientation, prescreen interview, USCIS interview, etc.).

4.2.5 Electronic Systems and Processing Requirements

Attaching or Connecting Devices: RSC staff must not connect any personal device to their

workstation or use a personal device to access any work-related content without written

authorization from the IT department and the RSC Director.

Prohibited personal devices include:

Cell phones (except with charge-only cable or adapter; if the workstation detects the

presence of the phone then it is not permitted)

Music players (e.g., iPod)

Thumb drives or external storage devices other than ones issued by the RSC and used only

for information related to WRAPS.

Monitors, headphones, mouse or keyboards, whether wired or wireless

Projectors

CD/DVD players or writers

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RSC staff must not connect any device to the WRAPS network except an RSC, USG, or RPC

provided laptop or desktop computer which is managed by RSC, the USG, or RPC and is up to

date on all patches.

Locked Screens: RSC staff must always lock their computer screens or other devices that

connect to the RSC network (email, WRAPS, RSC websites) when they are not in sight of their

workstation or device. Do not depend on the screensaver to lock the screen. Accounts will be

locked after five or more attempts to log in.

Printer Access: System Administrators at each RSC grant and maintain access for staff to access

printers in shared locations throughout the workspace. It is not permitted to print or scan

documents which contain USRAP data using a personal device without prior authorization from

the RSC Director or Deputy.

Saving Refugee Data: RSC staff must not save refugee data outside of designated electronic

workspaces and drives. This includes in any electronic workspaces that are not designed or

designated to process refugee data. RSCs may use cloud-based storage drives with prior written

approval from RPC Security (e.g., Office 365 tools). The use of such drives, whether cloud-based

or local, is conditional upon the drives being compliant with FIPS 140-2 encryption standards;

RSCs limiting the use of such drives to only RSC staff with need to know; and staff being

explicitly prohibited from downloading or sending documents from the drives to non-RSC issued

workstations, drives, or applications. RSCs must configure electronic workspaces and drives to

limit RSC staff access. Only RSC staff who have a demonstrated need to know should access the

refugee data in order to perform their job function. Only RSC staff should have access to the

platform unless the RSC has express approval from PRM/the RPC for a partner to access as well

(e.g. USCIS). RSCs should not allow refugee data to be downloaded onto non-RSC electronic

workspaces or drives.

All staff must have unique network logins which must be changed every 60 days. The password

must be at least 12 characters long, contain at least one number, one special character and one

upper case letter. Accounts must be immediately deactivated following departure of staff,

including WRAPS, email and any other RSC specific information. Additionally, group email

accounts must have unique network logins which must be changed every 60 days. Account

passwords must be immediately updated following departure of staff with access to the group

email account. Any access points that a departing staff member had access to must be changed

upon departure, to include, but not limited to, codes or passwords for physical access to facility

and all electronic access points. Staff must change all passwords that they use, i.e., door access,

safe access, etc., every 60 days.

For any suspected security incident impacting WRAPS/START data, report to the RPC Help

Desk and the RPC Security Team as soon as possible, and no more than 24 hours after becoming

aware of the incident. If PII data loss is suspected, the incident must be reported immediately, but

no later than four hours after the RSC became aware of the incident. For any suspected security

incident impacting the RSC network, but not impacting WRAPS/START data, report to the RPC

Help Desk and the RPC Security Team as soon as possible.

Access to WRAPS Database: Access to the WRAPS database must be limited to necessary

personnel only, as set forth in Section 2.0. RPC will control all access; all requests must be sent to

the RPC Help Desk. The RPC will review this access semi-annually and revoke when no longer

required.

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The RSC Director, in coordination with the RefCoord, must review the WRAPS and Tableau and

START (if applicable) twice a year to ensure robust integrity measures, or upon creation of a new

position, and make any necessary decisions about permissions. Although RefCoords do not need

to approve each individual employee’s access, they should approve the list of positions identified

by the RSC Director as needing WRAPS access, and the level of access required, in consultation

with the Program Officer as necessary. When an RSC is transitioned to START, user role and

group assignments will need to be reviewed and approved by PRM.

Additionally, the RSC must send a notification to the RPC Help Desk when a staff member ends

employment at the RSC to revoke all (WRAPS, Rsharenet, tokens, etc.) access and deactivate the

account.

Only authorized personnel can access the servers. WRAPS circuit ride servers must be physically

protected while in the field and while being returned to the RSC. These servers have to be disc-

encrypted and have anti-virus software installed. WRAPS servers must be physically protected

and secured, including at RSC sites and while on circuit rides.

4.2.5.1 Mobile Access Requirements

RSC management must limit access to office and electronic systems for staff to specific

hours, under supervision. These hours should be posted in an area where they are visible to

all employees in line with local time zones. Staff who need routine access to work email after

business hours must have written permission of the RSC Director/Deputy.

When accessing e-mail offsite using a work-issued computer, users are permitted to do so

using a secured VPN only. Any VPN used for offsite e-mail access should be approved by

RPC Security to ensure that its security features uphold those required by WRAPS. Webmail

should be disabled at the RSC. To limit the unauthorized disclosure of PII, PII information

should remain on the RSC network and should not be stored on personal devices.

The RSC must maintain an updated list of users who have been granted permission to:

Remotely access the RSC workstation and/or USRAP case management system. Note:

PO, RefCoord, and RPC leadership must approve remote access to the USRAP case

management system for RSC staff. RSCs must post the approved list on GitHub.

RSCs that have capability to monitor WRAPS remote log-ins should do so on a

monthly basis to ensure only approved staff are logging into WRAPS remotely and the

hours of log-in are not unusual.

Access VPN outside of normal working hours

Access work email on RSC-issued devices

Phone/Tablets: If the RSC Director/Deputy approves users to access work email and work-

related group email inboxes using an RSC-issued mobile device, those devices must be

remotely managed by the RSC. Any mobile application used to access work email must

follow the encryption standards specified in Section 3.2.

If an RSC-issued phone is used to access work email, a Mobile Device Manager (MDM)

must be installed and configured. MDMs must be approved by RPC Security prior to use. At

a minimum, the MDM should have the ability to carry out the following actions on each

device with e-mail access:

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Locate the device

Lock/unlock the device remotely

Wipe the device remotely

Apply security policies to the device as necessary

Separate emails and attachments from all other RSC phone applications

Prohibit attachments from email to be copied and entered into device applications and

prohibit attachments from device applications to be copied and entered into email

Restrict users from saving attachments locally on their phone

Prohibit copying/pasting from the email application to another application on the device

and vice-a-versa

RSC management may determine policies on limiting which apps can be downloaded and

used on RSC-issued phones/tablets. While the RPC does not restrict which apps may be

downloaded, any app used for communication with applicants must be explicitly approved by

the RPC for such purpose (see Section 3.1.5).

Generally, RSC staff with RSC-issued phones should use the phone for work purposes only.

Limited personal use may be permitted, if authorized by the RSC Director/Deputy, such as

sending a small number of non-work-related emails. Phones must not be used to make a copy

of sensitive information or PII from a screen by taking a picture/screenshot of it, recording a

video, or similar activities. Bluetooth should be disabled on RSC-issued phones. If staff

require the use of Bluetooth to complete RSC work, email your Program Officer with

examples of Bluetooth use to request approval.

Laptop: Staff must always lock the screen on their work laptop in the home office/workspace

area when the laptop is not in their sight. RSC staff must log out of the VPN once the

workday has been completed.

Virtual Private Network (VPN) Access: Access to workstations through a VPN is

authorized for RSC staff on official travel (including circuit rides) during the workday and in

official designated workspaces. Non-senior staff must have access to workstations after work

hours be approved by the RSC Director/Deputy.

The RSC is required to keep an updated list of users who have been granted permission to

access VPN outside of normal working hours.

VPN RSA Token: VPN RSA tokens may be used by staff approved by PRM/RPC to access

WRAPS remotely. If using a hard token, staff should store physical VPN RSA Tokens in a

secure location where it is not accessible by others in their environment if applicable.

Equipment must always be protected from potential theft or unauthorized use.

Work from Home Requirements: RSC Director/Deputy can approve work from home for

staff with a demonstrated need for remote access, and can approve work from home for

senior managers that involves accessing the WRAPS database through the VPN. However,

the RPC Director/Deputy must approve work from home that involves accessing the WRAPS

database for any non-senior managerial staff. RSCs are required to keep an updated list of

users who have been granted permission to work remotely on GitHub. Additional instructions

are available/updated on GitHub. Staff must only access WRAPS remotely through the

RSC’s VPN.

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RSCs are responsible for maintaining compliance with RPC requirements regarding the

security of their email systems.

4.2.6 Staff Orientation and Training

As part of annual training, any RSC staff with access to physical and/or electronic records that

contain refugee data must acknowledge, in writing, having read the entire Integrity and

Compliance module. All RSC staff who use an RSC computer connected to the internet must

annually acknowledge, in writing, they have read the WRAPS/START Rules of Behavior, even if

they do not have access to the WRAPS database. This is due to the fact that the WRAPS Rules of

Behavior contain useful information about protecting the network/computer while using the

internet. RSC Management should keep a record of these acknowledgements to ensure staff

compliance – an electronic signature/record of acknowledgement is acceptable.

RSC managers must review the above mentioned forms with new staff, particularly new staff

joining the RSC during remote work/work from home.

All staff with access to WRAPS/START and/or involved in case processing activities must also

receive annual trainings on ethics and fraud prevention, sexual exploitation, abuse prevention,

and, if necessary, the use of interpreters.

All staff are also required to take security training annually, including the RSC security training,

Department of State cyber security awareness training, and RSC headquarters’ security training.

Access to WRAPS may be suspended if training is overdue.

4.2.7 RSC Management Oversight

Where possible, managers must have line-of-sight over staff workspace in their section. If line-of-

sight is not feasible, managers must periodically walk around the premises to physically observe

staff. If staff are working from home, RSC Management must establish a regular check in

schedule with staff.

RSC management is responsible for developing quality controls (QC) and monitoring staff

compliance with SOPs through routine review of staff performance, work product, as well as

regular (at least semi-annual, unannounced pre-screening) observations for each staff member in

accordance with RSC management procedures for performance monitoring. Performance

monitoring should evaluate workplace conduct. RSC agency headquarters are to conduct annual

monitoring that includes fraud vulnerabilities, and submit results to PRM. If staff are found to be

out of compliance, management is to ensure adequate training and/or disciplinary measures.

RSC management is responsible for developing an effective QC process for ensuring different

staff review case files throughout the process, staff are completing the appropriate processing

steps, WRAPS is accurately updated, and maintenance of physical files is being done in a

complete and secure manner. Supervisors and management must develop random QC checks on

cases at key processing points (e.g. after PreScreen, after USCIS interview, before assurance

request, before travel, etc.). Directors should pick a reasonable sample size depending on the

number of cases in the pipeline.

RSC SOPs must be updated as relevant RPC SOPs are updated, at least quarterly, and sent to the

Program Officer for situational awareness. (Note: For RSCs using START, there will be a

different local SOP review/approval process led by the RPC.) SOPs should also be easily

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available to staff. If RSC SOPs deviate from RPC SOPs, the RSC must seek approval from the

Program Officer and the RPC. The change should be noted in the annual Compliance Matrix

report. Regular management and all staff meetings are to be held on monthly and semi-annual

schedules, respectively, at a minimum. If all-staff meetings are not possible due to space

limitations, senior staff should meet with each unit/department regularly and not less than twice a

year.

4.2.7.1 Processing – Quality Control

All case files should be reviewed at different steps by different staff throughout the process.

Quality control checks should be completed after each processing stage. RSCs should work

with the RPC to maintain and regularly update automated quality control reports to run

daily/weekly and catch any anomalies, including regular periodic review of the reports by

senior level managers. To ensure program integrity, staff must verify applicant identity at

every interaction and at the beginning of every activity.

In general, interviews should be scheduled based on application date – i.e., “first come, first

served” – except for urgent cases or other scheduling priorities per local SOPs or in

consultation with RefCoord or the PRM Program Officer. Expedite requests must be

approved in writing by a designated supervisor or manager prior to submission for PRM

authorization. For P-2 caseloads where RSCs grant access, any cases deemed “not qualified”

must be approved by a designated senior level manager, as defined by the RSC and

documented in writing.

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Document Change History The table below lists the changes in each version of this document.

Version Date Approved By Summary of Revisions

1.0 30 September

2020

Jen Smith Consolidated Program Integrity &

Compliance, Data Integrity &

Communications, Treatment of Refugee

Records, and Program Integrity Guidelines

into one document and updated information.

2.0 5 February

2021

Nicole Patel Updates to v1.0 based on RSC and RPC

Security Team review and feedback. Final

WRAPS update publication.