On April 25, CAIR-WA sent in a public comment to USCIS regarding their proposed rule on the collection of social media handles on immigration forms. We are sharing the comment in its entirety below.
April 25, 2025
Jerry L Rigdon
Acting Chief, Regulatory Coordination Division
Office of Policy and Strategy,
U.S. Citizenship and Immigration Services,
Department of Homeland Security
Re: Public Comment Opposing the Proposed Rule on Collection of Social Media Identifiers (OMB) Control Number 1615-NEW, Docket ID USCIS-2025-0003
CAIR Washington is writing to express our strong opposition to the proposed rule requiring the collection of social media identifiers on immigration forms according to the information collection instrument, (Docket No. USCIS-2025-0003) published in the Federal Register by the Department of Homeland Security on March 05, 2025. We are submitting this comment in advance of the close of the comment period on May 05, 2025. CAIR Washington is a Muslim Civil Rights and advocacy organization based in Washington state, and we appreciate the opportunity to provide input on the burden of collecting this information. This rule, if implemented, will have negative effects on Muslims, immigrants, and communities of color in our country, our state, and the communities we live in for the following reasons:
Disproportionate Impact on Muslim Communities and Civic Engagement
Muslim communities are already among the most heavily surveilled in the United States. In 2024, CAIR Washington conducted a survey of Muslims in Washington state, which provides crucial insights into the experiences of Muslims in Washington, with a focus on discrimination, political engagement, and policy priorities. The survey gathered responses from 684 Muslims across Washington state, with 542 completing the full survey. It highlights the diversity of Washington’s Muslim community, which includes South Asian, Arab, East African, Black American, Indigenous, and Latino Muslims, to name a few, with many other ethnic and racial backgrounds also represented. The Washington Muslim survey also found that 9% of Muslim respondents reported encounters with the FBI in the past year, and 1.1% experienced unannounced home visits by federal agents. These experiences foster an atmosphere of fear and mistrust in institutions. Our survey also found that: 91.7% of respondents have experienced discrimination in their lifetimes. 82.5% faced such discrimination within the past year alone, and 39% reported increased levels of discrimination since October 7, 2023, when the current violence against Palestine began. More than half of respondents expressed discomfort reaching out to public officials—citing fear of surveillance, retaliation, and lack of trust in institutions. Expanding government monitoring through mandatory social media disclosure would only deepen this divide, making it even harder for marginalized communities to participate fully in civic life and have their voices heard. This undermines community trust in institutions, and societal functioning. Communities can’t function together to the benefit of all when one group is targeted or excluded.
Ineffectiveness
There is little evidence to suggest that collecting social media identifiers meaningfully improves the immigration process, or national security. Immigration agencies already have access to comprehensive vetting tools. The immigration system is already underfunded and slow and immigration delays are extreme. Additional data collection will inhibit the government’s ability to produce accurate and efficient work for immigrant communities. Furthermore, all the information the government needs to make a decision on immigration applications can be found in the materials already included in the application process. Going beyond those parameters is out of scope and risks exacerbating an already overwhelmed immigration system.
Suppressive Impact on Free Speech and Advocacy
This proposed rule poses a threat to First Amendment rights. Young people, immigrants, and marginalized communities frequently use social media platforms to engage in advocacy, political discourse, and grassroots organizing. Requiring individuals to disclose their social media handles would act as a deterrent to free expression, discouraging people from speaking openly about issues such as immigration, civil rights, and geopolitical conflicts around the world. Across the country we are already seeing students like Mahmoud Khalil who are being detained or deported based on their political beliefs. This is unconstitutional, and immigration should not be used as a tool to prevent freedom of speech.
Disproportionate Burden on Youth
For adolescents and young adults, social media is a vital space for self-expression, and connection building. Muslim immigrant youth use online spaces to create community in their cultural and language group which may not exist in their daily lives. If students were required to reveal their social media information to the government, it may reduce avenues of connection to a group that is already experiencing isolation and exclusion, and would further limit Muslim immigrant youth from cultural and linguistic connections in crucial stages of life and development.
Furthermore, this rule, if implemented, would allow the government to make inferences about youth based on online behavior, which may be inaccurate. This puts the government in the position of evaluating youth behavior online and safety outside of any immigration eligibility basis. This is not the responsibility of the government when it comes to evaluating immigration applications.
Conclusion
The proposed rule is invasive, ineffective, and harmful to privacy, civil liberties, and democratic participation of immigrant and Muslim communities. CAIR-Washington register’s its strong objection to this proposed rule.