IMAGE

ICE Mutual Agreement Between Government and Employers

2010 IMAGE Training Session: Register Now

Join us for the 2010 IMAGE Training: Fostering Compliance through Education and Partnership session on August 9-10, 2010 in Arlington, Va.

Topics will include:

• Implementation of the new IMAGE best practices;
• Establishing an immigration compliance program;
• Proper hiring procedures;
• Fraudulent document detection;
• Use of the E-Verify employment eligibility verification program; and
• Anti-discrimination procedures.

The workshop will be held from 9 to 5 p.m. on August 9-10 at the Ritz-Carlton Pentagon City (1250 S. Hayes St, Arlington, Va., 22202). Room reservations at the hotel are available at $179 per night. Call 703-415-5000 to make your room reservation.

Register online for the training workshop.

Your Workforce Compliance Partner

U.S. Immigration and Customs Enforcement (ICE) is responsible for enforcing the nation's immigration and customs laws. One known vulnerability is the presence of undocumented workers who have secured jobs by fraudulent means, including presentation of false documents, completion of fraudulent benefit applications and theft of identities. To combat unlawful employment and reduce vulnerabilities that help illegal aliens gain such employment, the ICE Mutual Agreement between Government and Employers (IMAGE) program was initiated in 2007. The goal is to assist employers in targeted sectors to develop a more secure and stable workforce and to enhance fraudulent document awareness through education and training.

IMAGE Program

By voluntarily participating in the IMAGE program, companies can reduce unauthorized employment and the use of fraudulent identity documents. As part of IMAGE, ICE and U.S. Citizenship and Immigration Services (USCIS) will provide education and training on proper hiring procedures, fraudulent document detection, use of the E-Verify employment eligibility verification program and anti-discrimination procedures. Employers seeking to participate in IMAGE must agree to:

• Complete a self-assessment questionnaire;
• Enroll in E-Verify;
• Enroll in the Social Security Number Verification Service;
• Adhere to IMAGE Best Employment Practices;
• Undergo an I-9 audit conducted by ICE; and
• Review and sign an official IMAGE partnership agreement with ICE.

Upon enrollment and commitment to DHS's best hiring practices, program participants will be deemed "IMAGE Certified" – a distinction DHS believes will become an industry standard. The results of the IMAGE program and participation in IMAGE by partners in industry will serve to guide DHS in shaping future worksite enforcement policy and legislation.

IMAGE members participate in DHS's E-Verify employment eligibility verification program, administered by USCIS. Through this program, employers can verify that newly hired employees are eligible to work in the United States. This Internet-based system is available in all 50 states and is free to employers. It provides an automated link to the Social Security Administration database and DHS immigration records. To sign up for participation, visit the registration Web site https://www.vis-dhs.com/EmployerRegistration/.

Trade Association Membership

A parallel membership opportunity since the inception of IMAGE, trade associations can become "endorsee" partners by signing an endorsement agreement stating that they support and highly recommend the use of the IMAGE "Best Employment Practices" by their members.  The above-mentioned process for business entities is not required for association partnerships.

12 Best Hiring Practices

	Use E-Verify, the DHS employment eligibility verification program, to verify the employment eligibility of all new hires.
	Use the Social Security Number Verification Service (SSNVS) and make a good faith effort to correct and verify the names and Social Security numbers of the current workforce.
	Establish a written hiring and employment eligibility verification policy.
	Establish an internal compliance and training program related to the hiring and employment verification process, including completion of Form I-9, how to detect fraudulent use of documents in the verification process, and how to use E-Verify and SSNVS.
	Require the Form I-9 and E-Verify process to be conducted only by individuals who have received appropriate training and include a secondary review as part of each employee's verification to minimize the potential for a single individual to subvert the process.
	Arrange for annual Form I-9 audits by an external auditing firm or a trained employee not otherwise involved in the Form I-9 process.
	Establish a procedure to report to ICE credible information of suspected criminal misconduct in the employment eligibility verification process.
	Establish a program to assess subcontractors' compliance with employment eligibility verification requirements. Encourage contractors to incorporate IMAGE Best Practices and when practicable incorporate the verification requirements in subcontractor agreements.
	Establish a protocol for responding to letters received from federal and state government agencies indicating that there is a discrepancy between the agency's information and the information provided by the employer or employee (for example, "no match" letters received from the Social Security Administration).
	Establish a tip line mechanism (inbox, e-mail, etc.) for employees to report activity relating to the employment of unauthorized workers, and a protocol for responding to employee tips.
	Establish and maintain appropriate policies, practices and safeguards against use of the verification process for unlawful discrimination, and to ensure that U.S. citizens and authorized workers do not face discrimination with respect to hiring, firing, or recruitment or referral for a fee because of citizenship status or national origin.
	Maintain copies of any documents accepted as proof of identity and/or employment authorization for all new hires.

For more information on the IMAGE Program, please visit the IMAGE FAQ page. You may request an information packet via the IMAGE Information Packet Request form.