DHS ICE PIA 005a BMIS 2009

Privacy Impact Assessment Update
for the

Bond Management Information System
Web Version (BMIS Web)- Interface and
Collection Update
November 20, 2009
Contact Point
Daniel Ragsdale
Acting Chief Financial Officer
U.S. Immigration and Customs Enforcement
(202) 732-3000
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Abstract
The Bond Management Information System/Web Version (BMIS Web) is an immigration
bond management database used primarily by the Office of Financial Management (OFM) at U.S.
Immigration and Customs Enforcement (ICE). The basic function of BMIS Web is to record and
maintain for financial management purposes the immigration bonds that are posted for aliens
involved in removal proceedings. The Privacy Impact Assessment (PIA) for BMIS Web was
originally published in August 2008. Since then, the system interfaces and the scope of the
information collected have changed, thus necessitating an update to the PIA.

Introduction
BMIS Web is an immigration bond financial management database used primarily by the
Office of Financial Management (OFM) at U.S. Immigration and Customs Enforcement (ICE).
BMIS Web interfaces with the ICE Federal Financial Management System (FFMS) with regard to all
cash bond transactions, such as the posting of the cash bond and the disbursements paid to the
individual who posted the bond, in order to record the cash received and disbursed on the general
ledger of the financial records. Recently, ICE retired a system known as the Debt Collection System
(DCOS), which BMIS Web previously interfaced with to share information about surety bonds
where monies were owed to ICE. FFMS now performs the functions of DCOS, therefore, BMIS
Web now provides information about debts owed by surety agents to FFMS instead of DCOS.
FFMS creates invoices sent to surety agents regarding the debt, and tracks them from the time they
are created to the time the debts are paid.
In early 2010, ICE will deploy a new system known as eBONDS which will be used
primarily by surety agents and the ICE Office of Detention and Removal Operations (DRO) to
support the electronic request and approval of surety bonds for aliens in ICE detention.1 BMIS
Web and eBonds will interface electronically to exchange information about bonded aliens.
The information maintained in BMIS Web and exchanged through its interfaces is covered
under the Bond Management Information System (BMIS) System of Records Notice (SORN), 73
FR 52865, September 11, 2008. The BMIS SORN is being updated concurrently with the
publication of this PIA Update to include additional information (described below) that is
collected on bond obligors for cash bonds.

Reason for the PIA Update
This PIA is being updated to reflect changes in two electronic system-to-system interfaces
with BMIS Web, specifically the new eBONDS interface and the FFMS interface, that are described

1 The eBONDS PIA is available at www.dhs.gov/privacy. 

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in the paragraphs above. In addition, the PIA is updated to include additional information that ICE
collects on bond obligors for cash bonds that was not previously disclosed in the original BMIS
Web PIA. 2

Privacy Impact Analysis
In each of the below sections consider how the system has changed and what impact it has on the below 
fair information principles. In some cases there may be no changes and indicate as such.  

The System and the Information Collected and Stored within the System
In addition to the information collected from obligors previously described in the BMIS
Web PIA, DRO officers also collect the following information from cash bond obligors: citizenship
or immigration status, and a government-issued form of identification (for example, driver’s
license, green card, or passport) and identification number. A copy of the obligor’s identification
document is made as well. This information is collected on the I-352 Worksheet and is not input
into BMIS Web. The Worksheet and the copy of the identification document are placed in the
bonded alien’s Alien File (A-File). 3
The retirement of DCOS and transfer of the interface from DCOS to FFMS do not change
the type or amount of data collected or shared by BMIS Web.
The new eBONDS interface with BMIS Web does not change the type or the amount of
data collected or shared by BMIS Web. In a typical eBONDS transaction, a surety agent logs into
eBONDS to post a surety bond. Once a bond is initiated by the surety agent, eBONDS retrieves the
surety agent/surety company information and relevant Power of Attorney from BMIS Web, and
pre-populates that information into the online Immigration Bond Form I-352 to create a bond
documentation package. The surety agent completes the Form I-352 and submits the bond
documentation package to DRO. Once DRO approves the bond, the ENFORCE Alien Removal
Module (EARM) 4 converts the eBONDS record into the financial record of the bond in BMIS Web
to support the collection, reimbursement, or forfeiture of the bond principal, and the calculation
and payment of interest.

2 See BMIS Web PIA (August 25, 2008). 
3
The A-File is the record that contains copies of information regarding all transactions involving an individual as
he/she passes through the U.S. immigration and inspection process. Previously, legacy Immigration and
Naturalization Services (INS) handled all of these transactions. Since the formation of DHS, however, these
responsibilities have been divided among USCIS, ICE, and CBP. While USCIS is the custodian of the A-File, all
three components create and use A-Files. For additional information see the DHS-USCIS-001 Alien File (A-File)
and Central Index System (CIS) System of Records (72 FR 1755) available at www.dhs.gov/privacy.
4 EARM tracks the status of alien removal proceedings from initial arrest through the completion. For additional
information on routine uses and categories of individuals in EARM please see the ICE Removable Alien Records
(RARS) System of Record Notice (DHS/ICE-011, May 5, 2009, 74 FR 20719) at www.dhs.gov/privacy.

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Uses of the System and the Information
The collection of additional information from the obligor is necessary to confirm the
identity of the obligor and ensure that they have proper status in the country to post bond. This
data is not entered into BMIS Web, but is documented in the bonded alien’s A-File as evidence that
the obligor’s identity and immigration status were verified according to ICE procedures.
The disposition of DCOS and the performance of debt collection services by FFMS do not
change the use of the information. The use of FFMS for debt collection services is consistent with
the core financial accounting services already performed by FFMS as the ICE system for financial
obligations and payments processes.
The creation of the eBONDS interface supports a process modernization effort for the
management of immigration bonds. Through the new interface, BMIS Web makes the surety
agent/surety company information and relevant Power of Attorney available to eBONDS to
facilitate the posting of surety bonds online. This helps to ensure accuracy and consistency among
the different systems that deal with surety agent information. BMIS Web information is only
transmitted when a surety agent initiates a bond for a specific eligible alien. When DRO approves
a surety bond in eBONDS, EARM creates a financial record in BMIS Web.
The information transmitted between BMIS Web and eBONDS is necessary for the
enforcement of immigration bonds, including the administration of the bonds and associated
financial management activities. Immigration bond administration includes acceptance and
approval, declarations of breach, cancellation and referral for collection of breached bonds.
Associated financial management activities include collection, reimbursement or forfeiture of the
bond principal, and calculation and payment of interest. The eBONDS functionality that prepopulates the bond documentation package with BMIS Web information reduces the risk of
inaccurate data being submitted. The EARM functionality that creates a financial record in BMIS
Web for approved surety bonds creates a more efficient business process and ensures that data in
eBONDS and BMIS Web is accurate and consistent.
The risks of unauthorized use and inaccurate data raised by the FFMS and eBONDS
interfaces with BMIS Web are mitigated in several ways. The one-way interface from BMIS Web
to FFMS protects against unauthorized modification of the data and the further sharing of
inaccurate information. Further, the data fields completed by other systems in eBONDS are locked
to protect against alteration. ICE ensures that only authorized users have role-based access to BMIS
Web and to BMIS Web information. Audit controls at the database level for BMIS Web and its
interfaces are reviewed for individuals who are found to have accessed or used data in either
system in an unauthorized manner and such individuals are disciplined in accordance with ICE
policy. Further, ICE provides training to DHS federal employees and contractors on security and
privacy, and with regard to eBONDS, issues guidance to surety companies on how to handle
personal information.
Retention

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The FFMS and eBONDS interfaces do not change the retention period for information
maintained in BMIS Web. The information collected on the obligor for cash bonds is placed into
the alien’s A-File and maintained for the life of that file (75 years). United States Citizenship and
Immigration Services (USCIS) is responsible for the maintenance of an alien’s A-File.
FFMS may retain BMIS Web information for a longer period in cases such as open bonds or
bonds in trust because the financial event remains active pending further actions (e.g., closure or
breach of the open bonds or resolution of the owner of the bond for the return of funds).
eBONDS may retain BMIS Web information for a limited time to help surety agents
prepare a bond documentation package for submission to DRO. eBONDS deletes all bond
documentation packages that are not approved or are not submitted to DRO for approval one week
from the date when the record was initially created. eBONDS deletes all bond documentation
packages that are approved by DRO 48 hours after the surety agent acknowledges receipt of the
surety bond approval.
Internal Sharing and Disclosure
Internal sharing and disclosure of BMIS Web information are not changed with this
update.
External Sharing and Disclosure
The collection of additional obligor information and the BMIS Web/FFMS interface do not
change the external sharing and disclosure of BMIS Web information. When money is owed to
ICE on a surety bond, BMIS Web now sends the bond information to FFMS to be invoiced and
tracked until the time it is paid. Under the authority of 31 U.S.C. § 3711(e), FFMS may disclose
information to other agencies, such as the Treasury and Justice Departments, for debt collection
purposes if the surety bond is not paid in a timely manner. The information may also be disclosed
if an agent or bonding agency that posts surety bonds is being investigated for its financial
stability, licensing or business practices. The information is disclosed from FFMS, however, and
not from BMIS Web.
The BMIS Web/eBONDS interface does change the external sharing and disclosure of BMIS
Web information. Through eBONDS, information regarding the surety agent/surety company
and relevant Power of Attorney are made available to surety agents that access eBONDS through
their individual accounts. Although this new disclosure pertains to identified individuals, it is
limited to work-related contact information and is released to the individuals to whom it pertains.
The risk of over-disclosure and unauthorized access to BMIS Web information through the new
eBONDS interface is therefore very limited by the nature of the information shared and the fact
that sharing is limited to the individuals to whom the information pertains.
Notice
The BMIS Web SORN is being amended to include the additional obligor information
described in this PIA. This PIA Update, in conjunction with the amended Bond Management

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Information System (BMIS) SORN and the Privacy Act Statement on the Form I-352 and the
Worksheet, provide accurate information on the current stated uses and sharing of the
information. Such notice is sufficient to mitigate any risks associated with a lack of notice of the
collection of the information or the uses of the information.
Individual Access, Redress, and Correction
Individuals seeking notification of and access to any record contained in this system of
records, or seeking to contest its content, may submit a request in writing to:
ICE FOIA Officer
800 North Capitol Street, N.W.
5th Floor, Suite 585
Washington, D.C. 20528
Individuals may also submit requests by fax at 202-732-0310 or by email at [email protected].
Please see the ICE FOIA Office’s website for additional information
(http://www.ice.gov/foia/index.htm). If an individual believes more than one component
maintains Privacy Act records concerning him or her the individual may submit the request to the
Chief Privacy Officer, Department of Homeland Security, 245 Murray Drive, S.W., Building 410,
STOP-0550, Washington, D.C. 20528.
Further, the BMIS Web/eBONDS interface provides an additional means for surety agents
to access and correct their information. Surety agents may now access their own information by
logging into eBONDS. If they want to change or correct their information, i.e. their address or
phone number, then they must contact the surety company administrator, who will update the
information in eBONDS. eBONDS then updates the surety agent information in BMIS Web.
Technical Access and Security
User access to BMIS Web has not changed. FFMS and eBONDS users do not have direct
access to BMIS Web. Only authorized ICE personnel are given role-based access to BMIS Web, as
described in the BMIS Web PIA.
The BMIS Web/FFMS interface occurs behind the DHS firewall and supports the transfer of
information necessary to support debt collection and cash bond transactions. The interface uses
batch processing automatically executed by routine that is not accessible to BMIS Web users.
The BMIS Web/eBONDS interface occurs through secure web services, which provides
authentication, encryption, and message integrity, and supports the transfer of information
necessary for posting and managing surety bonds. Further, the data fields pre-populated by BMIS
Web cannot be modified by the surety agent.
The potential security risks to BMIS Web posed by the two interfaces are unauthorized
system access or use and inadequate system security. The risks are mitigated by securing the

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transfer of information and limiting the information to only what is necessary for the business
function.
The Certification and Accreditation process for BMIS Web was completed on August 15,
2008. The Certification and Accreditation process for FFMS was completed on January 17, 2007.
The Certification and Accreditation process for eBONDS is in progress but is expected to be
complete by December 2009.
Technology
The FFMS interface is in the operations and maintenance phase of the software life cycle
management process. The eBONDS interface will be deployed operationally in early 2010; the ICE
System Lifecycle Management methodology, Waterfall, was used for development. No technology
is used that might raise privacy concerns.

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

Approval Signature
Original signed and on file with the DHS Privacy Office.
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security