Agency Information Collection Activities; Proposals, Submissions, and Approvals: Petition to Classify Special Immigrant under the Immigration and Nationality Act as an Employee or Former Employee of the U.S. Government Abroad, etc.

Persistence Analytics Group LLC, a national security and infrastructure risk analytics firm, submits a comment regarding several State Department information collections. Rather than taking a simple position of support or opposition, the company argues that the Department should evaluate these collections through an implementation-verification framework to ensure identity accuracy, data integrity, and risk management.