Follow-up Review of the FBI’s Progress Toward Biometric Interoperability Between IAFIS and IDENT

Evaluation and Inspections Report I-2006-007
July 2006
Office of the Inspector General

This Background section describes the IAFIS, IDENT, and US‑VISIT systems; past efforts to achieve interoperability among the systems; the key agencies and working groups involved in the efforts to integrate the systems; and the findings from our December 2004 report that examined the status of the IDENT/IAFIS integration project and the disagreements between the Departments of Justice, Homeland Security, and State regarding development of an interoperable system. Fingerprint Identification Systems The IAFIS, IDENT, and US‑VISIT systems were designed by different agencies to provide fingerprint identification support for different requirements. A description of each system follows.24 IAFIS. The FBI developed IAFIS to store digitized fingerprints and criminal history records to assist federal, state, and local law enforcement agencies in identifying criminals. The FBI also built IAFIS to conduct non-criminal justice (civil) fingerprint background checks for employment and license applications and immigration benefits. Deployed in 1999, the IAFIS automated fingerprint identification system is operated by the FBI’s Criminal Justice Information Services (CJIS) Division. IAFIS contains the largest criminal biometric database in the world, the Criminal Master File, which stores over 50 million sets of 10 rolled fingerprints and corresponding criminal history information submitted by law enforcement agencies.25 IAFIS also contains a Civil Subject Index Master File, which stores non-criminal fingerprints (e.g., fingerprints of military, government, or authorized non-government personnel), and an Unsolved Latent File, which contains latent fingerprint images found at crime scenes. IDENT. The former Immigration and Naturalization Service (INS) developed IDENT to identify and track individuals apprehended for illegally crossing the U.S. border and to identify recidivists (i.e., those apprehended more than once).26 Deployed in 1994, IDENT is an automated fingerprint identification system that matches two flat fingerprints from the right and left index fingers of apprehended aliens against similar fingerprint records contained in a database of over 55 million subjects that includes legitimate travelers and immigration violators.27 Those fingerprint records are organized into distinct enforcement- and immigration-related data bases:28 Lookout database: The Lookout database contains approximately 920,000 unique fingerprint records, as well as photographs and basic information, for aliens who have been previously deported or who have criminal records. The FBI provides the DHS with some of the data by extracting certain categories of records from IAFIS and sending them to IDENT. Those records include: Known or Suspected Terrorists: Approximately 31,000 fingerprint records from individuals detained by the U.S. military, the FBI’s most wanted terrorists, and records from certain field investigations. Wants and Warrants: Approximately 800,000 records of individuals with active warrants from the Wanted Persons file of the FBI’s National Crime Information Center.29 The FBI initially provided only those “Wants and Warrants” records that met the DHS’s screening criteria of individuals who are foreign born, have no place of birth listed, or who have had previous encounters with immigration officials documented in IAFIS. However, the FBI now also provides fingerprint records of U.S. citizens with new or recently updated active warrants. Recidivist database: The Recidivist database contains over 8.3 million unique fingerprint records and photographs of aliens who have been previously apprehended. Those records include the following categories: Apprehensions: Approximately 7.8 million fingerprint records of previous DHS and legacy INS enforcement actions. Alerts: Approximately 658,000 fingerprint records of previous DHS and legacy INS encounters that may require special attention at a subsequent encounter, such as “armed and dangerous” or an officer safety alert. The alerts also include approximately 390,000 “Expedited Removal” records for aliens that have been removed from the United States because they lacked proper documentation or committed fraud when attempting to enter the United States. Previous Criminal History: Approximately 446,000 fingerprint records of individuals from 25 high-risk countries, such as Iraq, Iran, Syria, and Sudan. The FBI provided these records as a one-time transfer and included demoted Wants and Warrants records. US‑VISIT. The DHS developed US‑VISIT as an entry/exit tracking system to collect, maintain, and share information on foreign nationals (visitors) in the United States so that immigration officials can determine whether these individuals should be prohibited from entering the country, have overstayed or violated the terms of their admission, or should be detained for law enforcement action. Deployed in January 2004, US-VISIT uses IDENT to collect two flat fingerprints and a digital photograph to provide the biometric identification for visitors. The fingerprints are taken either at ports of entry when the visitors arrive or by Department of State (DOS) employees at visa‑issuing consulates before the visitors arrive. The first time a visitor’s fingerprints are taken, they are checked against the US‑VISIT Watch List database (a “one-to-many” comparison) and enrolled into the US‑VISIT Enrollment database by the DHS (at ports of entry) or the DOS (at consulates).30 The US-VISIT Watch List and Enrollment databases contain the following records from IDENT: US-VISIT Watch List database: The US-VISIT Watch List contains approximately 1.7 million unique fingerprint records of aliens who have been previously deported, previously apprehended, or who have been denied a visa. Those records include the entire Lookout database, plus: The previous criminal history records (in the Recidivist database), The Expedited Removal records (in the Recidivist database), and “Visa Denial” records, formally called “Biometric Visa Application Category 1 Critical Refusals,” constituting approximately 16,000 fingerprint records from applicants whose visas were denied because the DOS determined that they posed a substantial risk to the United States.31 US-VISIT Enrollment database: The US-VISIT Enrollment database contains over 43 million unique fingerprint records of foreign nationals who have visited the United States or applied for an immigration benefit, such as a visa or a Border Crossing Card. According to the DHS, the US-VISIT Enrollment database has been increasing by approximately 80,000 fingerprint records per day since 2004. Interoperability of Fingerprint Identification Systems IAFIS and IDENT were not designed to be interoperable. The FBI and the INS began discussing integrating IAFIS and IDENT in the early 1990s when the two systems were in their development stages. However, the agencies had a difference of opinion, stemming from the different purposes of the systems, as to whether the INS should collect 2 or 10 fingerprints from apprehended aliens. The FBI created IAFIS to automate its Criminal Master File and serve the needs of the law enforcement community. Because fingerprints at crime scenes may be from any finger, the law enforcement standard requires that officers take prints from all 10 fingers of a subject. Conversely, the INS created IDENT as an internal system to track aliens apprehended illegally crossing the border between ports of entry and to subsequently identify those who illegally crossed the border more than once. Because the INS frequently apprehended large groups of aliens that had to be processed quickly, taking 10 rolled fingerprints was deemed too time-consuming, and IDENT therefore was designed to use only 2 fingerprints. Congress directed that fingerprint identification systems be interoperable. Since the late 1990s, Congress has expressed concern that IAFIS and IDENT could not share data readily. After the terrorist attacks of September 11, 2001, Congress required that federal fingerprint identification systems be made interoperable so that aliens and visitors to the United States who are criminals or known or suspected terrorists can be more readily identified. In the 2001 USA PATRIOT Act (Patriot Act), Congress required a “cross-agency, cross-platform electronic system that is a cost-effective, efficient, fully integrated means to share law enforcement and intelligence information necessary to confirm the identity of... persons applying for a United States visa....”32 The Patriot Act specified that this system be “readily and easily accessible” to all consulates, federal inspection agents, and law enforcement and intelligence officers responsible for investigating aliens. In the Enhanced Border Security and Visa Entry Reform Act of 2002 (Border Security Act), which amended several provisions of the Patriot Act, Congress changed the description of the electronic system from integrated to interoperable. The Border Security Act, in its description of an “interoperable data system,” required that immigration authorities have “current and immediate” access to information in federal law enforcement agencies’ databases to determine whether to allow aliens to enter the United States.33 Congress directed that the NIST develop a technology standard for interoperability. One of the requirements in the 2001 Patriot Act was for the Attorney General and the Secretary of State, working jointly with the National Institute of Standards and Technology (NIST), to develop a technology standard for verifying the identity of foreign nationals when they apply for visas at U.S. consulates and when they arrive at ports of entry.34 In response to this requirement, the NIST issued a Technology Standard in January 2003 for collecting fingerprints from foreign nationals. The NIST Technology Standard called for 10 flat fingerprints to be collected for initial enrollment into automated systems and for 2 flat fingerprints and a digital photograph to be used to verify an individual’s identity against an existing enrollment record. US-VISIT did not incorporate the NIST Technology Standard. Notwithstanding the NIST’s January 2003 recommendation of 10 flat fingerprints as the Technology Standard for enrolling individuals in automated systems, on July 18, 2003, the Homeland Security Council Deputies Committee approved US-VISIT’s use of 2 flat fingerprints and a photograph to enroll individuals during the system’s initial deployment at sea and air ports of entry.35 In September 2003, the DOS began deploying single-finger scanners at its consulates to prepare for the enrollment of visa applicants into US‑VISIT. On January 5, 2004, the DHS launched US‑VISIT at air and sea ports of entry.36 Integrated IDENT/IAFIS Workstations In 2004, the DHS began deploying integrated IDENT/IAFIS workstations that allow DHS personnel to directly search IAFIS using 10 rolled fingerprints, and simultaneously enroll individuals into IDENT using 2 fingerprints.37 The purpose of the integrated workstations was to provide immigration authorities with access to criminal history information in IAFIS. Border Patrol agents use those workstations to check all aliens apprehended crossing the border illegally. In addition, inspectors at ports of entry use the workstations to check a small number of aliens who are referred to secondary inspection and denied admittance into the United States. However, the integrated workstations do not meet the goal of full interoperability because they are not multi‑directional; the FBI and other law enforcement agencies do not have direct access to the DHS’s IDENT. When the DHS transmits an alien’s fingerprints to IAFIS using the integrated workstations, it uses a transaction referred to as a Ten-Print Rap Sheet (TPRS). TPRS transactions provide a quick response to searches of aliens’ fingerprints. When the DHS transmits an alien’s fingerprints to IAFIS, the system searches its Criminal Master File for a potential “hit” or match. If the alien’s fingerprints generate a potential match, IAFIS returns the criminal history file. Key Agencies and Working Groups Department of Justice. The Department’s Justice Management Division (JMD) has maintained oversight of the integration of IAFIS and IDENT since 1999. The Department’s Chief Information Officer (CIO) manages the integration project for the Department and represents the Department in meetings with the DHS and other agencies. The FBI’s CJIS Division maintains and operates IAFIS. Department of Homeland Security. The DHS’s Bureau of Customs and Border Protection (CBP) employs Border Patrol agents and inspectors, whose mission includes preventing terrorists and criminal aliens from entering the United States and apprehending individuals attempting to enter the United States illegally. The US‑VISIT Program Management Office (US-VISIT office) manages US‑VISIT and is responsible for communicating with Department of Justice representatives and participating in interagency meetings. CBP and the US-VISIT office report directly to the DHS Deputy Secretary. Department of Commerce. Scientists at the Department of Commerce’s NIST have been working with the FBI for over 30 years to research, develop, and improve fingerprint-matching procedures. They are currently working with representatives from the Department of Justice, the FBI’s CJIS Division, DOS, and DHS in regular interagency meetings and joint studies regarding fingerprint biometrics. Department of State. The DOS’s Bureau of Consular Affairs is responsible for administering laws, formulating regulations, and implementing policies relating to consular services and immigration, including issuing visas (both immigrant and non-immigrant), and passports to U.S. citizens. Representatives from the Bureau of Consular Affairs work with the Department of Justice and the DHS on biometrics issues and participate in the interagency meetings regarding fingerprint identification issues. Homeland Security Council Deputies Committee. The Homeland Security Council Deputies Committee is responsible for ensuring coordination of all homeland security-related activities among executive departments and agencies. It is the senior sub-Cabinet interagency forum for consideration of policy issues affecting homeland security, including fingerprint biometrics, and comprises officials at the deputy level (or their designees) from the Department of Justice, DHS, DOS, and other agencies. The Deputies have met regularly since January 2004 to discuss security issues, including the interoperability of IAFIS, IDENT, and US‑VISIT. Policy Coordination Committee. Formed in January 2004, the Policy Coordination Committee reports to the Homeland Security Council Deputies on various executive branch issues, including current and future use of the fingerprint data contained in IAFIS, IDENT, and US‑VISIT. The Policy Coordination Committee is managed by the Office of Management and Budget, and its participants include representatives from the Department of Justice, DHS, and DOS. Integrated Project Team. Formed in May 2005, the Integrated Project Team’s (IPT) mission is to achieve interoperability of biometric (e.g., fingerprint) information in the databases of the FBI and the DHS, and to share related biographic (e.g., name, date of birth, social security number), criminal history, and immigration information in real time or near real time with each other and federal, state, and local law enforcement agencies.38 The IPT includes representatives from the CJIS Division, the US-VISIT office, and the DOS, with occasional participation from the NIST and other officials. Within the Department of Justice, the Office of the CIO is responsible for monitoring the IPT and its progress and the CJIS Division is the lead component responsible for system development activities.39 The IPT consists of an Executive Committee and three sub‑teams: Business Requirements, which ascertains requirements from interoperability stakeholders and establishes operational consensus; Information Technology, which reviews the stakeholders’ requirements and advises the IPT on the most feasible technical solutions and logical approaches to design, development, and implementation; and Strategy and Policy, which ensures that the interoperability plan is consistent with FBI and DHS strategies and policies. In September 2005, the IPT created two working groups to address different aspects of the interoperability effort. The Unique Identity IPT, led by the DHS, is addressing the modifications needed to enable US-VISIT (via IDENT) to make the transition to a 10-fingerprint enrollment standard.40 The Interoperability IPT, led by the FBI, is addressing all other issues related to making IAFIS interoperable with the DHS’s systems. Officials from the FBI and the DHS participate on both working groups and are responsible for jointly implementing interoperability between IAFIS and IDENT. December 2004 OIG Report on the Integration of IAFIS and IDENT In our 2004 review, we reported that efforts to achieve full interoperability had stalled because of two major barriers. The Department, DHS, and DOS still had not agreed on either a uniform method for collecting fingerprint information or on the extent to which federal, state, and local law enforcement agencies are to have access to the DHS’s immigration records. We also found that the DHS was using data extracted from IAFIS to supplement IDENT and was checking most visitors’ fingerprints against only IAFIS extracts, which created a risk that criminal aliens or terrorists could enter the United States undetected. Regarding the FBI, we found that IAFIS capacity was sufficient to handle the DHS’s projected daily workload, but the FBI was not prepared to process a large volume of flat fingerprints from the DHS and was not meeting its IAFIS availability requirement of 99 percent. The Department, DHS, and DOS did not agree on a fingerprint collection standard. The first major barrier to achieving interoperability between IAFIS and IDENT that we identified in 2004 was that the Department, DHS, and DOS had not agreed on a standard for collecting fingerprint information from foreign nationals applying at consulates for visas to visit the United States or seeking admission to the United States at ports of entry. The Department endorsed the NIST Technology Standard of 10 flat fingerprints for enrolling visa applicants and visitors in US‑VISIT because 10 fingerprints would reduce the number of false positives and offer more options for system design and interoperability.41 We also reported that the agencies were using various fingerprint collection methodologies: Department/FBI: The Department’s standard was to collect 10 rolled fingerprints for enrollment in IAFIS, although the Department acknowledged that 2 flat fingerprints could be used by the DHS to subsequently verify aliens’ identities by checking the aliens’ fingerprints against their own enrolled records. DHS: The DHS was collecting two flat fingerprints at ports of entry to enroll visitors into US‑VISIT. However, the DHS was also collecting 10 rolled fingerprints (to check against IAFIS) from apprehended aliens at Border Patrol stations and from visitors referred to secondary inspection at ports of entry who were not going to be admitted to the United States. DOS: The DOS was collecting two flat fingerprints at U.S. consulates to enroll individuals applying for visas into US‑VISIT. See Appendix I for a table comparing the fingerprint collection methods used by the three agencies. The Department, DHS, and DOS did not agree on how to provide law enforcement agencies with access to the DHS’s immigration records. The second major barrier to achieving interoperability that we identified in 2004 was that the DHS and the Department disagreed on a method of providing federal, state, and local law enforcement agencies with the “readily and easily accessible” access to the IDENT database specified in the Patriot Act and in subsequent congressional legislation. Also, the DHS did not believe that the FBI or other law enforcement agencies should have access to US-VISIT records. The DHS maintained that position for several reasons, including that the information in IDENT is incomplete and could be misinterpreted, and the privacy of visitors enrolled in US-VISIT must be protected. However, the OIG report noted that without direct access to the DHS’s IDENT database, it is more difficult for federal, state, and local law enforcement agencies to identify illegal aliens they encounter. The DHS used data extracted from IAFIS to supplement IDENT. In our 2004 review, we described how, because the systems are not interoperable, the FBI is periodically providing the DHS with records extracted from IAFIS to supplement information in the IDENT Lookout database. However, there was some delay between when records are extracted from IAFIS and when they are entered into IDENT. For example, the FBI was providing the Known or Suspected Terrorists records to the DHS approximately once a month. Further, a Department Metrics Study found some of the extracts to be incomplete and prone to errors, which could allow criminals or terrorists whose data has not been extracted from IAFIS to use falsified identity papers to gain entry into the United States.42 For example, one of the DHS’s selection criteria for referring visitors to secondary inspection relies upon self-reported data (e.g., place of birth), but aliens being arrested may lie about their nationality to avoid deportation. Also, many U.S. citizens have an unknown or foreign place of birth. That selection criteria was particularly problematic for the Wants and Warrants extracts because the records of U.S. citizens may be loaded into the IDENT database, while the records of some non-U.S. citizens and potential criminal aliens are not included. The Metrics Study found that the Wants and Warrants extracts failed to include 22 percent (121 of 541) of criminal aliens with active wants and warrants. The DHS checked most visitors’ fingerprints only against IAFIS extracts. Our 2004 report also noted that the DHS was planning to limit direct IAFIS fingerprint searches (TPRS transactions) to a small percentage of visitors who are referred to secondary inspection and not admitted to the United States.43 According to the DHS’s workload projections through 2005, only about 800 visitors per day – or 0.7 percent of the total projected visitors required to be enrolled in US‑VISIT in 2005 – would be subjected to direct IAFIS TPRS searches at ports of entry.44 The other 99.3 percent of visitors enrolled in US‑VISIT would be checked against the US‑VISIT Watch List, which contains extracts from IAFIS, but not against the full IAFIS Criminal Master File. We found that the DHS’s practice of checking 99.3 percent of the visitors’ fingerprints only against the limited data extracted from IAFIS and contained in the US‑VISIT Watch List increased the risk of admitting criminal aliens. As the Metrics Study showed, searching individuals directly against IAFIS resulted in a significant increase in the number of criminal aliens identified. At the time of our 2004 review, the Department was interested in determining the risk posed by not checking all visitors against IAFIS. The Department proposed conducting a study to compare data from US-VISIT and other relevant immigration biometric databases against IAFIS. Also, we noted that while the IAFIS capacity of 20,000 daily TPRS transactions was sufficient to handle the then-projected DHS daily workload, if the DHS made a policy decision to request TPRS transactions on all visitors sent to secondary inspection, the resulting workload could exceed the IAFIS capacity. The FBI was not prepared to process flat fingerprints from the DHS. In 2004, we found that the FBI had recognized that it needed to upgrade IAFIS to begin accepting flat fingerprints (in lieu of rolled) for non-criminal justice (civil) purposes, such as in the case of employment and license applications or immigration benefits. At that time, the FBI had received approval from its National Crime Prevention and Privacy Compact Council to accept flat fingerprints, but had not yet begun receiving them.45 Further, although the FBI planned to begin conducting flat fingerprint searches, it was not prepared to process the large number of searches that would be required if the DHS were to start submitting 10 flat fingerprints from all visitors enrolled into US-VISIT. IAFIS was not meeting its availability requirement. In our 2004 review, we found that IAFIS was not meeting its availability requirement of being accessible to users 99 percent of the time. We determined that from November 2003 through April 2004, IAFIS was unavailable for a total of 161 hours, resulting in an average monthly availability of 96 percent. As a result, it was possible that some aliens whose criminal records were in IAFIS but not in IDENT would be released and allowed to enter the United States due to the system’s unavailability. For example, if IAFIS results are not received within about 10 minutes, which may happen if IAFIS is unavailable, immigration officials must make their decisions on whether to further detain aliens based only on the results of IDENT queries. Consequently, some criminal aliens who would have been identified through IAFIS queries may not be detained. The OIG made six recommendations in our previous report. In our December 2004 report, we concluded that for the Department to effectively proceed with making IAFIS interoperable with the fingerprint systems of the DHS and the DOS, high-level policy decisions needed to be made regarding who should be subjected to fingerprint searches, the fingerprint collection standard to be used, the databases to be queried, who should have access to the information, how the information should be used, and who should maintain the databases. We recommended that the Department seek to have the federal government address those decisions in a timely way. We made the following six recommendations to the Department: Within 90 days of the enactment of the Department’s FY 2005 appropriations act, report to the Homeland Security Council and Congress that the Department, the DHS, and the DOS have reached an impasse and cannot complete the [memorandum of understanding] directed by Congress.46 The report should formally request that the Homeland Security Council or Congress decide on the adoption of the NIST Technology Standard and define the capabilities to be provided in the interoperable system; Increase the transmission of the fingerprints of Known or Suspected Terrorists from the FBI to the DHS from monthly to at least weekly; Request access to a random sample of data from US-VISIT and other relevant immigration biometric databases used for enforcement or benefit purposes for comparison to IAFIS in order to determine the risk posed by not checking all visitors against IAFIS; Coordinate with the DHS to identify the capacity needed to conduct IAFIS searches on all visitors referred to secondary inspection and inform the Department’s CIO how the capacity of IAFIS (now planned to be 20,000 searches by October 1, 2005) could be increased to handle that level of activity; Develop options for the eventual upgrade of IAFIS to enable the system to conduct 10 flat fingerprint searches on all US-VISIT enrollees and TPRS submissions from the Border Patrol and from the ports of entry; and Take steps to ensure that IAFIS meets its availability requirement of 99 percent. As described in the Results of the Review section, our current review has found that the Department and the FBI have taken steps that were generally responsive to all of the recommendations we made in our December 2004 report. Footnotes For a more detailed description and history of each system, see the OIG’s December 2004 report, Follow-up Review of the Status of IDENT/IAFIS Integration, Background and Appendix I, www.usdoj.gov/oig/reports/plus/e0501/index.htm. The Criminal Master File records follow the law enforcement standard of taking prints from all 10 fingers by rolling and pressing each finger on either a scanner or a standard paper fingerprint record form (10 rolled prints). Fingerprints also may be taken by pressing fingers straight down (flat fingerprints) and from fewer than 10 fingers. On March 1, 2003, the INS was transferred to the DHS and its operational responsibilities divided among the Bureau of Customs and Border Protection, the Bureau of Immigration and Customs Enforcement, and the Bureau of Citizenship and Immigration Services. According to the DHS, IDENT processes 150,000 to 230,000 daily fingerprint identifications and verifications. IDENT also contains an Asylum database of approximately 501,000 fingerprint records entered and used by immigration officers who process asylum claims, and a Border Crossing Card database of approximately 7.5 million fingerprints of Mexican citizens that is used by DOS officials who process Border Crossing Card applications. The 800,000 Wants and Warrants reflect the number of records that the DHS had received from the FBI as of June 6, 2006. However this number changes regularly due to the addition of new records and the removal of “demoted” records, which are Wants and Warrants that are no longer active. When visitors subsequently enter the United States, their fingerprints are matched only against their own enrolled fingerprints (a “one-to-one” comparison) to verify the visitors’ identity. Although visitors’ fingerprints are compared to those on the Watch List, they are not searched against IDENT’s Apprehension, Asylum, or Border Crossing Card databases. However, DHS officials have informed us that by the end of fiscal year (FY) 2006, all IDENT databases will be searched during the US-VISIT process. USA PATRIOT Act (P.L. 107-56), Section 403(c)(2). Enhanced Border Security and Visa Entry Reform Act of 2002 (P.L. 107-173), Section 202(a)(2). After the DHS’s creation through the Homeland Security Act of 2002, the responsibility for immigration-related issues shifted from the Department of Justice to the DHS. The Homeland Security Council Deputies Committee, organized under the Executive Office of the President, is responsible for ensuring coordination of all homeland security-related activities among executive departments and agencies. As of December 30, 2005, US‑VISIT was operating at 115 airports, 15 seaports, secondary inspection areas at 154 land ports of entry, and approximately 214 visa-issuing consulates. Secondary inspection refers to designated areas at ports of entry that allow inspectors to conduct additional screening to verify visitors’ information without causing delays to other arriving visitors. On September 21, 2004, the DHS reported that it had deployed IDENT/IAFIS workstations to all 142 Border Patrol stations. The DHS then deployed the workstations to all 284 air, land, and sea ports of entry on December 19, 2005. Integrated workstations have also been deployed at 342 Immigration and Customs Enforcement sites. According to the FBI, “near real time” means that information will be updated within 24 hours. However, the FBI plans to update this information more quickly after September 2006. Officials from JMD’s Management and Planning Staff stated that they are becoming less involved in guiding interoperability efforts since the formation of the IPT, while the Office of the CIO and the CJIS Division have taken more active roles. According to the IPT’s Concept of Operations and a US-VISIT official we interviewed, the term “unique identity” refers to the biographic information connected to an individual’s unique set of fingerprints. False positives occur when the system incorrectly determines that a search fingerprint and a file fingerprint are matches. JMD, Cost and Operational Effectiveness Analysis, Second Report to Congress, August 27, 2004. Visitors are referred to secondary inspection if a search in any of the law enforcement/immigration databases queried at primary inspection results in a hit or if they raise the suspicion of the primary immigration officer. Visitors exempt from US-VISIT include those with certain designated visa classifications, children under the age of 14, persons over the age of 79, Mexican nationals to whom the DOS has issued Border Crossing Cards for use along the southern border, and Canadians entering the United States across the northern border. The Compact Council governs the use of the Interstate Identification Index system of criminal history record information for non-criminal justice purposes, according to the National Crime Prevention and Privacy Compact Act of 1998. The Interstate Identification Index is a segment of IAFIS that stores textual criminal history information on arrests and dispositions of criminal subjects. In addition, the Compact Council advises the CJIS Advisory Policy Board on civil fingerprint standards. In our March 2004 report, we recommended that the Department work with the DHS to develop and implement a memorandum of understanding to guide integration of IAFIS and IDENT. The Conference Report accompanying the FY 2004 omnibus appropriations legislation also directed the Department to develop such a document with the DHS and other appropriate federal agencies regarding the continued integration of fingerprint systems.