IMAGE

Homeland Security Investigations (HSI)’s IMAGE program is a formal membership certification program that focuses on exceptional employers that have the ability to effect change within their industry or region. These employers also serve as an example and role model in the business community while highlighting the importance and viability of immigration compliance. Program participants will be deemed IMAGE certified upon enrollment and completion of IMAGE membership requirements. Employer feedback on the IMAGE program and industry participation in IMAGE will serve to guide DHS in shaping future labor exploitation policy.

By voluntarily participating in the IMAGE program, companies can reduce unauthorized employment and the use of fraudulent identity documents. As part of IMAGE, HSI and U.S. Citizenship and Immigration Services (USCIS) will provide education and training on proper hiring procedures, fraudulent document detection and use of the E-Verify employment eligibility verification program. Members will also learn about the importance of avoiding discrimination in violation of the Immigration and Nationality Act’s anti-discrimination provision § 274B.8 U.S.C. § 1324b.

Employers seeking certification in IMAGE must agree to:

• Complete the IMAGE Self-Assessment Questionnaire (SAQ) and Statement of Interest (SOI)
• Submit to a Form I-9 Inspection
• Enroll in the E-Verify program within 60 days
• Establish a written hiring and employment eligibility verification policy that includes an internal Form I-9 audit at least once a year
• Review and sign an official IMAGE membership agreement with HSI

Upon enrollment and commitment to DHS' best employment practices, program participants will be deemed "IMAGE Certified" – a distinction DHS believes will become an industry standard. The results of the IMAGE program will guide DHS in shaping future labor exploitation policy and legislation.

IMAGE members are required to participate in E-Verify, an Internet-based system that compares information from an employee's Form I-9, Employment Eligibility Verification, to data from U.S. Department of Homeland Security and Social Security Administration records to confirm employment eligibility. For more information about the Form I-9 visit I-9 Central, a website dedicated to making guidance more accessible and user-friendly. The site provides employees and employers with one online location to keep them up to date with the information needed to properly complete Form I-9.

The Department of Justice Immigrant and Employee Rights Section (IER), enforces the anti-discrimination provision of the Immigration and Nationality Act § 274B, 8 U.S.C. § 1324b. This statute prohibits discrimination in hiring, firing, or recruitment or referral for a fee that is based on an individual's national origin or citizenship status. The statute also prohibits discrimination during the employment eligibility verification (Form I-9 and E-Verify) process (document abuse), and retaliation or intimidation.

For more information see "How Employers Can Avoid Discrimination in the Form I-9 and E-Verify Processes".

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.

For more information on the IMAGE program, please visit the IMAGE FAQ section. You may request additional information via the Information Request Form.

IMAGE Membership Benefits

• Public recognition of the employer's IMAGE membership;
• Avoidance of lawsuits and other legal actions resulting from unauthorized employment;
• Brand name protection;
• A stable workforce;
• No Form I-9 inspection for a minimum of four years; and
• HSI provided training and guidance on proper hiring procedures and fraudulent document awareness

• Establish an internal compliance and training program related to the hiring and employment verification process, including, but not limited to, the completion of the Form I-9, how to detect the use of fraudulent and not-relating documents in the verification process, and how to use E-Verify and current Social Security Administration systems.
• Require that the Form I-9 and the E-Verify process be conducted by individuals who have received appropriate training and that it includes a secondary review as part of each employee’s employment eligibility verification in order to minimize the potential for a single individual to subvert the process.
• Arrange for annual internal Form I-9 audits by an external auditing firm, law firm, counsel or a trained employee not otherwise involved in the Form I-9 process.
• Establish a procedure to report to HSI credible information of suspected criminal misconduct in the employment eligibility verification process.
• Encourage contractors to incorporate IMAGE Best Practices and, when practicable, incorporate the IMAGE verification requirements in subcontractor agreements.
• Establish a protocol for responding to letters or other information received from federal and state government agencies and indicating that there is a discrepancy between the agency’s information and the information provided by the employer or the employee (for example, “Employer Correction Request” letters received from the SSA) and provide employees with an opportunity to make a good faith effort to resolve the discrepancy when it is not due to employer error.
• Use the Social Security Number Verification Service (SSNVS) for wage reporting purposes. Make a good faith effort to correct and verify the names and Social Security numbers of the current workforce and work with employees to resolve any discrepancies.
• Establish a written hiring and employment eligibility verification policy.
• Ensure that contractors and/or subcontractors establish procedures to comply with employment eligibility verification requirements. Encourage contractors and/or subcontractors to incorporate IMAGE Best Practices and when practicable incorporate the use of E-Verify in subcontractor agreements.
• Establish and maintain appropriate policies, practices, and safeguards against the use of the employment eligibility verification process for unlawful discrimination, and to ensure that those authorized to work in the United States do not face discrimination with respect to hiring, firing, 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.

Becoming an IMAGE (ICE Mutual Agreement between Government and Employers) member is now easier than ever.

This training lasts from 8:30 a.m. to 5:00 p.m. and comprises Form I-9 training, USCIS E-Verify updates, Office of Special Counsel training and fraudulent document detection training. If you're an employer, join IMAGE for a series of forums across the country.