• Not All Electronic Storage is Created Equally
  • November 8, 2012 | Authors: Laurie M. Chess; Mary Ellen Jordan
  • Law Firms: Jones Walker LLP - Miami Office ; Jones Walker LLP - New Orleans Office
  • At least not in the view of the United States Immigration and Customs Enforcement ("ICE"). In August 2010, ICE enacted the Electronic Signature and Storage of Form I-9 Verification Rule. This rule allowed for electronic completion and storage of the I-9 Form, provided there was a clear audit trail of actions taken with respect to each form. Two years later, the U.S. Department of Homeland Security issued guidance for its agents and auditors with respect to collecting these forms in an audit or investigation and analyzing the audit trail.