Audit Objectives

The objectives of the audit were to: (1) determine whether accurate and complete records are disseminated to and from the Terrorist Screening Center’s (TSC) watchlist database in a timely fashion; (2) review the TSC’s efforts to ensure the quality of the information in the watchlist database; and (3) assess the TSC’s efforts to address complaints raised by individuals who believe they have been incorrectly identified as watchlist subjects.

Scope and Methodology

We performed our audit in accordance with Government Auditing Standards issued by the Comptroller General of the United States, and accordingly, included such tests of the records and procedures that we considered necessary. Our audit covered but was not limited to the period of June 2005 through April 2007.

To accomplish our objectives, we conducted work primarily at the TSC, located in the Washington, D.C., metropolitan area. Additionally, we interviewed personnel at other federal agencies and offices whose work relates to TSC operations, such as NCTC, the FBI, DHS, and the White House Privacy and Civil Liberties Oversight Board.

To obtain an overall understanding of the TSC’s role and responsibilities, we reviewed legislative materials related to the TSC’s creation and watchlisting requirements, prior audit reports, and various other documents as needed, including financial documents, strategic plans, and staffing reports.

Accuracy and Completeness of Database Records

To obtain an understanding of the TSC’s processes and procedures for ensuring the quality of data ingested into and exported from the Terrorist Screening Database (TSDB), we reviewed the TSC’s procedures for processing database nominations and encounters. In addition, we interviewed:

• Contractors and representatives from the various participating Departments working within the TSC’s Administration Branch, Operations Branch, Information Technology Branch, Call Center, Nominations and Data Integrity Unit, and other support areas.

• Program managers at NCTC.

• Supervisors from the FBI’s Terrorist Threat Center, Terrorist Review and Examination Unit, and Terrorist Screening Operations Unit.

• The Executive Assistant Director of the FBI’s National Security Branch and the Assistant Director and Deputy Assistant Director of its Counterterrorism Division.

Testing of Watchlist Database Records

As of March 16, 2007, there were 689,613 records in the web-based version of the TSDB. We performed various tests of a limited number of these records, and reviewed related records from the pertinent automated data systems used to store terrorist-related information maintained by the NCTC and FBI, to determine whether the records were accurate and complete, and any record changes were made in a timely fashion. The automated data systems were the TSDB, TSC’s Encounter Management Application (EMA), NCTC’s Terrorist Identities Datamart Environment (TIDE), and the FBI’s Violent Gang and Terrorist Organization File (VGTOF).

In addition to querying the TSDB to identify duplicate records and determining whether records related to 20 FBI requests for removal had been deleted from the TSDB in a timely manner, our tests of judgmentally selected records included:

• Review of 50 TSDB records related to 25 FBI international terrorist and 25 FBI domestic terrorist nominations to determine whether basic identifying information [SENSITIVE INFORMATION REDACTED] listed on the FD‑930 (the form used by the FBI for watchlisting nominations) were accurately entered into the databases. In addition, we analyzed key dates shown on the FD‑930s to determine whether the names and other information were entered into the TSDB in a timely fashion.

• Review of a sample of 49 known terrorist names to determine whether the basic identifying information as well as citizenship and physical characteristics were accurately entered into the databases. Of these names, 10 were non-FBI originated international terrorist identities in the TIDE database, 17 were selected from the FBI’s Most Wanted Terrorists list, 2 were selected from the Rewards For Justice website, 16 came from the State Department’s Office of Counter Terrorism, and 4 were obtained from various newspaper articles.

• Review of 51 TSDB records for which TSC staff had identified as having quality assurance issues, such as missing, outdated, or inaccurate information.⁷⁰ This review included identifying the quality assurance issue that was raised, determining whether the appropriate changes had been made to the TSDB, TIDE, and VGTOF records. In addition, we evaluated the timeliness of the revision and any additional follow-up performed by TSC staff to ensure that the necessary changes were made. Finally, we reviewed these records to determine whether the basic identifying information was accurately entered into the databases.

• Review of 20 TSDB records related to positive encounters with watchlist subjects, as recorded in EMA, to determine whether the basic identifying information was accurately entered into the databases and information obtained by law enforcement agencies as a result of the encounters was added to appropriate database records.

• Review of 15 TSDB records that TSC staff identified as having undergone a thorough quality assurance review as part of a special project to evaluate the adequacy of the TSC’s review and to determine whether the basic identifying information was accurately entered into the databases.

Finally, we compared information in the TSDB records to watchlisting criteria to determine whether the individuals were nominated for the appropriate watchlists and were assigned an appropriate handling instruction.⁷¹

Watchlist Redress

To obtain an understanding of the TSC’s role in the terrorist watchlist redress process and its efforts to reduce watchlist misidentifications, we reviewed the TSC’s redress procedures and the U.S. government’s interagency agreement on terrorist watchlist redress. We judgmentally selected and examined 20 redress complaints reviewed by the TSC Redress Office to evaluate whether the TSC followed its Redress SOP for resolving a redress complaint.

We also conducted interviews with the TSC’s Privacy and Redress Officers, and we reviewed the TSC’s strategic plan to identify any goals related to redress or reducing the incidence and effect of watchlist misidentification. Additionally, to obtain an understanding of the partner agencies’ roles in the redress process and how they coordinate with the TSC, we interviewed representatives from the White House Privacy and Civil Liberties Oversight Board, the DHS’s Screening Coordination Office, TSA, and CBP.

From January 2005 through February 2007, 438 redress complaints were referred to the TSC. During this same period, the TSC closed 388 complaints. We performed various analyses of TSC’s redress referral data, including calculating:

• the percent of cases referred to the TSC according to referring agency;

• the average amount of time cases were open, and evaluating the reasons affecting delays in closing the matters; and

• the TSC’s disposition for its closed redress matters.

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70. 25 of the 51 records were selected from the TSC’s Quality Assurance Tracker, the TSC’s original system for monitoring TSDB records with quality assurance issues. The remaining 26 records were selected from quality assurance tickets, the TSC’s current monitoring system.

71. The criteria used by the agencies hosting TSDB records are identified in Appendix II.