The Department of Homeland Security has never published guidance on electronic storage of the Form I-9, but has indicated that IRS standards for electronic storage would be considered adequate. In fact, the Immigration and Customs Enforcement (ICE) website does endorse the use of electronic storage, since the I-9s are most likely stored in a format that is easier to inspect and can be readily accessed as part of an integrated E-Verify system in which an employer may already be enrolled.

Federal Requirements

Currently, the law requires that an electronic storage system provide: Reasonable controls to ensure the integrity, • accuracy and reliability of the electronic generation or storage system,

Reasonable controls designed to prevent and detect the unauthorized or accidental creation of, addition to, alteration of, deletion of, or deterioration of an electronically completed or stored Form I-9, including the electronic signature if used..

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