Yellow Jacket InitiativeBy E. Lawrence Anderson, Yellow Jacket Initiative
Update, Tuesday, November 3, 2026. This post cites SSA's Master Files notice (60-0058) as modified November 12, 2025 (90 FR 50879). A federal district court vacated that notice on June 22, 2026; the Supreme Court stayed that order on September 25, pending appeal. On November 3, SSA published a new version of 60-0058 (91 FR 69297) that does not include the November 2025 routine use to DHS under 8 U.S.C. 1373(a). Routine use 4 quoted below is now routine use 3 in the new notice, with the same wording. Follow-up: SSA re-issues its master Social Security number file notice without the routine use that gave DHS citizenship data under 8 U.S.C. 1373(a). The original text below is unchanged.
The Social Security Administration is creating a new system of records, the Client Data System (60-0392). The notice was published in the Federal Register on Friday, October 30, 2026, at 91 FR 68581 (FR Doc 2026-22173, Docket SSA-2025-0030), after going on public inspection October 29. It is signed by Matthew Ramsey, SSA's Head of Privacy and Disclosure Policy. Every quotation below was checked against the published notice on October 30, 2026.
The innocent reading, first.
SSA describes a customer-service tool. The system will "track data fields that are maintained in multiple SSA systems to help ensure consistent information across systems," giving staff "one main location to view information concerning the customer." On its face this is consolidation of data SSA already holds, not new collection. SSA says it reported the system to the Office of Management and Budget and Congress, as the Privacy Act requires (5 U.S.C. 552a(r)).
What the system holds.
It covers "individuals who have been issued a Social Security number (SSN), including those who have conducted business with SSA beyond enumeration." Records include:
- identity information: name, SSN, sex, date of birth, parents' names, place of birth;
- "Citizenship Information: This information may include country of citizenship";
- contact information, including email, language, phone, and opt-ins for electronic messaging.
Records are retrieved by SSN. Listed purposes include tracking customer interactions and authorizations ("consent for disclosure for in-person identity proofing purposes, consent to text"), "identity verification of SSA customers, prevention of fraud," and staffing and planning decisions.
Who can receive it.
The notice lists 30 routine uses. Most are standard SSA language: congressional inquiries, the National Archives, breach response, Justice Department litigation, contractors, and benefit programs. Two bear on our subjects:
- Routine use 17: "To Department of Homeland Security, upon request, to identify and locate aliens in the United States pursuant to section 290(b) of the Immigration and Nationality Act (8 U.S.C. 1360(b))."
- Routine use 30: the Treasury Department's Do Not Pay system, to identify, prevent or recoup improper payments.
Routine use 17 is not new SSA language. The same sentence, with one added abbreviation ("(DHS)"), appears as routine use 4 in SSA's Master Files of SSN Holders and SSN Applications notice (60-0058), as modified November 12, 2025 (90 FR 50879). The new system carries that existing disclosure into a combined view of each number holder's record. It does not include the master file's other citizenship-related routine uses, such as E-Verify.
Dates.
The notice applied on publication, October 30. Its new routine uses take effect Monday, November 30, 2026, and the notice asks for comments by the same day. Comments go to docket SSA-2025-0030 at regulations.gov.
What is not established.
We have not compared all 30 routine uses with every SSA notice they may come from. Whether this system changes what reaches DHS in practice is not stated in the notice. Why a notice published in October 2026 carries a 2025 docket number is not stated.
Why we follow it.
Our research tracks where federal identity and citizenship records are combined and who can reach them. This notice combines both for everyone with a Social Security number, under a disclosure to DHS that already existed.
Primary source: Social Security Administration, Privacy Act of 1974; System of Records, Client Data System (60-0392), 91 FR 68581 (Oct. 30, 2026) (PDF). Compared with: Master Files of SSN Holders and SSN Applications (60-0058), 90 FR 50879 (Nov. 12, 2025).
Read the text.
Independent Research. All Documents Freely Reproducible.