60 Day FRN Comment Matrix

Form G-1595-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2023-0017-0001
60-day FRN Citation (federalregister.gov): 88 FR 83956
Publish Dates: December 1, 2023 – January 30, 2024
Comment #
1.

Commenter ID

1a.

0003

Comment
Commenter: Justicia Lab (See comments broken
down as Items 1a. – 1c.)

USCIS Response
NOTE: The commenter uploaded a
letter to regulations.gov at this link
0003. USCIS reviewed the three (3)
recommendations provided in the
letter and listed them as items 1a. –
1c. in this matrix so USCIS may easily
review and if needed, address each
recommendation. The letter also
includes background about the
commenter, Justicia Lab and can be
reviewed at the link to the letter
above.
Clarify Whether Separate Submissions Are
Response:
Required for Each Application
As a security best practice, each
While Form G-1595 (API (Application Programming application will require separate
credentials. Each application can also
Interface) Production Access Request) is
be governed by separate terms and
straightforward and user-friendly overall, we
conditions, so each application will
recommend additional instructions to better
need to submit documentation
understand the intended purpose of the
separately. USCIS will modify the
questions.
language accordingly.
“Part 1. Verification,” “Part 2. Contact
Information,” and “Part 3. Information About Your
Company or Organization” ask for information
about the Organization and App. However, it is
unclear if an Organization should complete the API
request form for the organization or if it will need
to complete the form for each application using
the USCIS’ APIs.
Citizenshipworks is one of several tools built by
Justicia Lab that can benefit from leveraging
USCIS’s API. We suggest that USCIS specify if an
organization should complete separate forms for
each tool/app that the organization intends to
connect to USCIS’s API or if completing one form is
sufficient for using USCIS’s APIs.

1b.

0003

Send Notifications to an API Endpoint
“Part 3: Information About Your Company or
Organization” asks the organization to provide a
“Notification Email address for API Status updates
(Required) (Question 4). It seems that should a
status update about the API need to be shared, an
email notification will be sent to the organization

Response:
USCIS will consider this suggestion.

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Form G-1595-001 NEW - Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2023-0017-0001
60-day FRN Citation (federalregister.gov): 88 FR 83956
Publish Dates: December 1, 2023 – January 30, 2024
directly; we also recommend the ability to receive
the notification/status update via an API endpoint.
Receiving these notifications via an API Endpoint
will allow us to display within the application that
made the API call and more easily communicate
with our users.
1c.

0003

Clarify Timing of User Consent to Changes in
Privacy Policy and Terms of Service
“Part 5. Requirements for Privacy and Terms of
Service: Privacy and Data Practices” list
requirements asking the organization to “Specify
that you will get active consent from users when
changes are made to privacy policies and terms of
service.” We commend the need to protect the
privacy of all users and welcome further
clarification regarding this requirement. We
recommend that USICS provide further
clarification as to whether users' active consent
must be gathered before changes to privacy
policies and/or terms of service are implemented.

Response:
USCIS will modify the language to
clarify.

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