First off there are the concerns raised by Attorney Woodruff. There are no guarantees on how the information collected will be used and how long the data will be kept. I think it’s safe to say that ICE can get a hold of that data, if they so desire. Fortunately, that is a minor concern for most legal residents of the CNMI. There are bigger issues at stake.

I don’t claim to be a lawyer, but I remember from back in my school days that the Paperwork Reduction Act governs how federal government agencies gather data. It’s my understanding that all proper and legal requests for information must have an OMB control number on the form to ensure that the form complies not only with the law but also that the data collected truly is required by the government. Furthermore, it states just how the data may be used and for what purposes it may be used.

I looked very closely at the registration form prepared by the Federal Ombudsman’s Office and there is no OMB control number. There is also no Paperwork Reduction Act notice on the form. These facts alone mean that the registration form is not compulsory. You can fill it out if you want to, but there is no requirement to do it. It’s almost frightening to see that the form doesn’t have any statements on how exactly the data will be used and who will have access to that data. Some may find solace in the statements of the Ombudsperson that the data will be used only for the count of aliens, but without an OMB control number and a clear Privacy Act statement, we can only trust her and every other alphabet soup government agency that could possibly access the information.