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Replies should be forwarded to Mr. Benny L. Kass, Assistant Counsel of the Subcommittee, no later than October 1, 1966.
Detailed.—Description of record(s) filed : This column is to be as general as possible, but with sufficient description to enable the Subcommittee to analyze the rest of the form.
Column (a): Enter on a separate line the code number for each type of information held, as given in the attached appendix, entitled “Code for reporting types of information in Column (a).” However, where the data to be provided in columns (b) to (j) are the same, related items may be combined and shown on one line. (For example, the entry in column (a) might read “1, 3, 4 and 7”). Do not attempt to cover items of information other than those listed. Information on the agency's own employees as such will be obtained through the Civil Service Commission and should not be listed here
Column (6): Indicate in a phrase the precise group of individuals covered. Examples: “all veterans”; “veterans applying for housing loan guarantee”; “individuals in Current Population Survey sample”; “Selective Service registrants.” If the coverage of distinct bodies of your records of a given type is differently defined the covered groups may be listed on separate lines without regard to possible duplication.
Column (c): For each covered group of individuals defined in column (b) give the approximate number of individuals covered by your records regardless of the age of the records (going back only as far as 1900), and regardless of whether in current files or records centers. Estimates to the nearest 100,000 will be satisfactory (Use “*” to indicate less than 50,000).
Column (d): If individual records of the type listed are currently generated by a program of the agency, indicate the estimated annual rate at which new records are acquired (without regard to duplication with existing records, except that monthly or other periodic reports from the same individuals should be counted only once annually).
Column (e): Indicate in terms of the broad classes defined below the source of the information, using the following code. The first four categories refer to data obtained directly from the individuals covered.
Stat.: Statistical reports or surveys.
Coop: Shared records of cooperating public or private agencies. Column (f): Indicate, using the following code, whether the date were obtained from the individual on a compulsory or voluntary basis. Note that certain procedures, neither strictly voluntary nor strictly mandatory, are designated “Conditional”.
Mand.: Mandatory. Data obtained under express or implied compulsion. Vol.: Voluntary. Data obtained through voluntary cooperation of the
respondent. Cond.: Conditional. Data required as a condition for an application, for
participation in a program, for the award of a contract, etc. Column (9): Indicate, whether the data for individuals are subject to confidentiality restrictions, and the basis of confidentiality, as follows; (with citation of any statute):
Statute : Confidential by specific statute.
None: No guarantee of confidentiality. Column (h): If the data are subject to confidentiality restrictions, indicate the unit within which the data are held confidential. Explain briefly any procedures for exceptions to this rule.
Bureau : Not disclosed beyond collecting office of bureau.
Column (i): Indicate the form on which the data referred to is stored. Use the following categories :
Eye: Eye Readable.
Mnly: Manually Retrieved.
CODE FOR REPORTING TYPES OF INFORMATION IN COLUMN (A)
15. Welfare status and history. Financial information:
16. Income: total and/or by sources.
21. Checking and Savings accounts. Housing:
22. Home ownership.
25. Condition of living quarters. Education :
26. Highest grade completed or degree (s) earned. 27. Grade average or class standing.
28. Knowledge of foreign languages. Employment and occupation :
29. Occupation : current and/or past.
33. Recommendations and references. Legal and investigational information:
34. Police Record.
36. Involvement in civil or criminal court action. Health:
37. Medical history.
41. Alcoholism or drug addiction. Consumer interest :
42. Food purchases and consumption.
Inventory of information on individuals in the records of Federal agencies
Upon receipt of the agency answers, the Subcommittee arranged with the General Accounting Office to borrow the services of one of their Supervisory Accountants, Mr. John H. Carney. Mr. Carney performed a most valuable function by collating and compiling all of the information. A memorandum summarizing Mr. Carney's work follows (the views expressed in this memorandum are the views of Mr. Carney and do not necessarily represent either those of the General Accounting Office or of the Senate Subcommittee on Administrative Practice and Procedure):
To: Benny Kass, Assistant Counsel, Subcommittee on Administrative Practice
and Procedure From: John H. Carney, Supervisory Accountant, General Accounting Office
Subject: Summary of work performed in the analysis of Senate Questionnaire
My objective in undertaking this project was to review and analyze in detail the completed Senate questionnaires returned by the various Federal Departments; Independent Agencies; and selected Boards, Committees and Commissions and designed to obtain information currently maintained about identifiable individuals in the files of Federal agencies in order to evaluate this information and determine whether or not excessive data is required and obtained from individuals.
Since the rapid advancement in computer technology has created the definite possibility for a National Data Center, there is an ever-growing concern that the individual citizen's privacy can and will be invaded. By the mere push of a button, it will be entirely possible to coordinate information from various sources on a given individual and obtain a "cradle-to-the grave" report about him. Naturally, having the ability to coordinate this information has unlimited statistical merit, but a happy medium between these two computer potentials must be reached.
In light of the above, I received and analyzed the questionnaire returns and the following general observations should be made:
(1) Government contractors, consultants, and their employees are required to submit such information as the birthplace of parents, income, legal, investigational, and health data as a condition to securing a potential job and in some cases, no confidentiality is extended on this data.
(2) The Selective Service System requires all registrants under the Universal Military Training and Service Act to supply legal and investigational information such as police records, security or other investigative reports, and any involvement in civil and criminal court action. All additional information such as religious or financial information is only required from those registrants seeking a deferment for such reason.
(3) Certain agencies require their top or key employees to furnish certain financial information on a "Statement of Employment and Financial Interest”.
(4) Forms 57, credit reports, and agency personnel files contain an excessive amount of information about an individual such as the birthplace of his parents, his income and assets, and certain health information such as a personality inventory and alcoholism or drug addiction traits.
(5) Most medical and police forms require the individual to list his race. This would be permissable if it is used for statitical purposes only.
(6) Security clearance tend to require the individual to list most of the information cited in the questionnaire. However, since the individuals securing a clearance will have access to classified records, it is essential that this detailed information be obtained.
(7) Applicants for the Government's various grants and fellowships are required to usually divulge their police record, security or other investigative reports, and any involvement in ciivl or criminal court action. This information appears to be excessive and nonessential as long as all academic requirements are fulfilled.
CONCLUSIONS AND RECOMMENDATIONS
It appears that the majority of Government forms require either nonessential or too detailed information from the individual citizen. However, for the following two reasons, the results achieved through a thorough examination of Government forms could not justify the work that would have to be performed, unless it could be statistically programmed for computer use:
(1) The various forms are too voluminous;
(2) one would have to have a good working knowledge of both the agency and the purpose of each form in order to evaluate it adequately.
Also, in concluding, some mention should be made on the use of the confidentiality with respect to the Government's handling of data obtained from the individual. In many instances, the individual is required either on a mandatory or conditional basis to complete certain forms; however, the limits of confidentiality have been either non-existent or a pledge not to dis ose ou the Government has been given. This pledge cannot be too meaningful since the Government is quite a large organization.
Based on the above conclusions, I recommend that this project be directed to general trends in Government data collection methods (agency forms) rather than become "bogged down" in specific agency forms. Also, it should be suggested to the various Federal agencies that they take a hard look at their statutes or other agency regulations pertaining to confidentiality standards in order to determine that the maximum protection is being afforded the individual with respect to the personal data which he has surrendered.
(A committee print is now being prepared which will give in detail the departments and agencies responses to the subcommittee questionnaire.)
NATIONAL ASSOCIATION OF MANUFACTURERS,
Washington, D.C., March 23, 1967. Hon. EDWARD V. LONG, Chairman, Administrative Practices and Procedures Subcommittee, U.S. Senate, Washington, D.C.
DEAR MR. CHAIRMAN : In response to a public notice of the Federal Communications Commission that it was launching an inquiry re computers, NAM wrote Chairman Rosel Hyde, November 11, 1966, that it "welcomed the opportunity to participate.”
Our letter pointed out that industry felt adequate safeguards to protect individual privacy and proprietary information should be built in to any proposal to set up a Government data bank.
Subsequently, NAM established a Computer Subcommittee of its Telecommunications Committee, composed of industrial experts in this field, to prepare for participation in the FCC inquiry.
It is our sincere belief, since the FCC is engaging in an inquiry regarding the regulation and use of computers, that the protection of individual privacy and
proprietary information should be high on the list of considerations given exhaustive study. We will continue efforts to impress the importance of this matter upon the attention of the FCC as its inquiry progresses.
We know the Subcommittee of which you are Chairman is also vitally interested in this consideration, and it has occurred to us, accordingly, that you may wish to advise the FCC that Congress, and especially your Committee, is interested in having this matter fully explored by FCC as a logical and necessary part of its inquiry. Such a declaration of interest, we feel certain, would do much to insure desired attention. Your assistance is respectfully requested and will be much appreciated. Sincerely,
LEO V. BODINE. P.S.—Enclosed, for your information, is copy of a report by C. L. Hutchinson, Chairman of the NAM Computer Subcommittee, on his recent participation in a symposium held at Airlie.
REPORT BY C. L. HUTCHINSON, AFIPS CONFERENCE, AIRLIE FOUNDATION,
WARRENTON, VA., MARCH 5, 6, 7, 1967 This conference, sponsored by the American Federation of Information Processing Societies (AFIPS), was devoted to probing the relationships between the issue of individual privacy and the idea of at National Data Center or Data Bank. The legal, legislative, sociological, economic, administrative and, to a limited degree, the technological aspects were discussed by qualified representatives from the fields involved. A list of the attendees is attached. Most of the discussions covered subjects which had appeared in print previously in one form or another. The outstanding value of the conference lay in the fact that the many aspects of the problem were related to each other and evaluated in an overall context.
The Airlie Conference was primarily concerned with the issues of privacy in the proposed National Data Center. The parallel problem of privacy in the business environment, which is at least of equal importance, was not considered in any detail.
The National Data Center concept is of recent origin since it is based on current advances in computer technology and information systems. The concept was advanced by Richard Ruggles, a Yale University economist in his capacity as chairman of a committe of the Social Science Research Council. A copy of the Ruggles Report was presented to the Bureau of the Budget which then assigned Edgar S. Dunn, Jr., a consultant, to evaluate the report. His evaluation is known as the "Dunn Report". Later, the Bureau named a committee chaired by Carl Kaysen of the Institute for Advanced Study to report on the “Storage of and Access to Government Statistics”. The report of this committee is known as the "Kaysen Report”. All three reports recommended the creation of a National Data Center or Data Bank. Publicity concerning the concept created a furor over the possibility of invasion of individual privacy and led to an investigation by a subcommittee of the House Committee on Government Operations. Cornelius E. Gallagher is chairman of this subcommittee which held hearings in July 1966 on “The Computer and Invasion of Privacy" and is continuing its surveillance.
The concept of a National Data Center to improve the collection, storage, manipulation, and retrieval of government statistics has much to recommend it if invasion of privacy can be and will be adequately protected. However, no comprehensive study has yet been completed to determine cost effectiveness, improved usefulness, or in fact, just how such a system would be implemented. Current technology, however, is such that National Data Center could be implemented. It would be a very large undertaking that would require many years to complete.
The degree to which invasion of individual privacy can be prevented in a National Data Center has not yet been clearly established. Under the present government systems such protection is left largely to the individual agencies respon