This report focuses on data protection for undocumented or mixed-status beneficiary households. In the context of cash-based assistance (CBA) programs, poor data protection practices could add additional risks for low-risk individuals by providing data trails that could pave the way for unauthorized access to applicant or beneficiary data or leakage of personally identifiable information. These could leave a digital footprint that can make it easier for law enforcement to target undocumented individuals.

Considering these risks, we have identified and detailed approaches and strategies used to protect applicant and beneficiary data through four programmatic phases: targeting beneficiaries, outreach and onboarding, disbursement and distribution, and ongoing monitoring and data storage/retention. Insights in this report are gleaned from CFI interviews with cities, community-based organizations (CBOs), debit card providers, and privacy advocates.

This report is intended to guide municipal officials and CBOs considering or developing programs to support undocumented or mixed-status households. The insights may also be of interest to organizations advocating for and supporting the rights of undocumented populations, students and academics, and anyone interested in access to financial and public services for all members of U.S. communities.

Alex Rizzi

Senior Research Director, Consumer Data Opportunities and Risks

Since joining CFI in 2012, Alex has been an advocate for consumer protection and evidence-based inclusive finance practices.

She manages the responsible data practices research portfolio at CFI which focuses on opportunities and risks for low-income consumers from data-driven financial services. Previously, she was a senior director for CFI’s Smart Campaign initiative, where she managed consumer-protection learning agendas and helped launch the Client Protection Certification Program.

Prior to joining CFI, Alex was a project development manager at Innovations for Poverty Action, where she helped create its microsavings and payments innovation initiative (now part of its global financial inclusion initiative), a research fund focused on impact evaluations of savings products and payment systems. She also worked at the Centre for Microfinance at IFMR Research (now Krea University) in Chennai, India, where she was the head of knowledge management and dissemination.

She has participated in multiple industry working groups on responsible finance, including an advisory group to GSMA’s mobile money certification program and the Microfinance Center’s social performance fund steering committee.

Alex is a graduate of Princeton University and holds a master’s degree from Georgetown’s foreign service school, as well as a certificate in digital money from the Digital Frontiers Institute and The Fletcher School at Tufts University. She speaks conversational French and needs to work on her Italian.

Madeleine Longwell

Former Research Assistant

Maddy assisted with research and data analysis for CFI’s workstreams, including financial health, climate, and municipal cash transfers. Previously, she was the program coordinator for the HBS-Accion Program on Strategic Leadership in Inclusive Finance. Before joining CFI, Maddy was a research assistant at the Institute for International Economic Policy,  where she focused on national artificial intelligence strategies and data trade policy. She was also an editorial intern at Defense News. Maddy holds a bachelor’s degree in economics from George Washington University.

Explore More

Privacy as Product, FSP designers
Toolkits and Guides

Privacy as Product: Privacy by Design for Inclusive Finance

Sign up for updates

This field is for validation purposes and should be left unchanged.