Attorney General Charity Clark has joined 17 other state attorneys general in challenging the Trump Administration’s move to expand the Systematic Alien Verification for Entitlements (SAVE) program. The expansion would allow the collection of personal data from U.S.-born citizens who have not interacted with the immigration system and did not consent to this use of their information.
The SAVE program is an online tool run by U.S. Citizenship and Immigration Services that enables state and local agencies to verify immigration status for individuals applying for public benefits or licenses, such as driver’s licenses, service in the armed forces, SNAP, or Medicaid. On October 31, 2025, the Department of Homeland Security (DHS) issued a “Systems of Record Notice” (SORN), which broadens access within SAVE to include information about all natural-born U.S. citizens using identifiers like social security numbers, passport numbers, and driver’s license numbers.
The DHS notice also introduced two new uses for collected data: sharing it with federal organizations to audit programs at state and local levels, and allowing searches across multiple cases simultaneously. According to Attorney General Clark and her counterparts, these changes reflect attempts by the federal government to formalize modifications to SAVE that had already begun earlier in the year.
In a letter sent to DHS, Clark and other attorneys general urged that these changes be withdrawn. They argued that incorporating more data sources could increase errors in records regarding citizenship or immigration status. States such as Vermont may face added administrative burdens verifying inaccurate responses from SAVE—a process described as time-consuming and individualized—which could result in delayed or denied benefits for residents or improper removal from voter rolls.
The coalition also raised concerns about security risks tied to amassing sensitive personal information on all Americans in one system. They warned that such databases could become targets for hackers or foreign actors, especially when third parties are granted access.
Additionally, they contend that expanding SAVE without providing natural-born citizens a chance to participate in decisions about their data violates the Privacy Act of 1974.
“Security concerns are even greater when federal agencies enlist the help of unknown third parties and provide them with access to Americans’ sensitive personal information,” stated Attorney General Clark and her colleagues in their comments submitted alongside attorneys general from California, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, New York, Oregon, and Rhode Island.
