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Prepared by the OMB, this document provides guidance on how the recordkeeping provisions of the Privacy Act of 1974 affect agencies' programs (so-called "call detail programs") to collect and use information relating to their employees use of long distance telephone systems.
- Describes the purposes of call detail programs and explains how they work.
- Notes that call detail records that contain only telephone numbers are not Privacy Act records, but that when linked with a name they become Privacy Act records.
- Notes that when agencies start retrieving by reference to a linked number or name, they are operating a Privacy Act system of records.
- Urges agencies not to create artificial filing and retrieval schemes to avoid the Privacy Act.
- Suggests agencies establish a Privacy Act system of records in which to maintain these records. and provides a model notice for them to use.
- Discusses the disclosure provisions of the Privacy Act as they would pertain to such a call detail system, especially emphasizing that intra-agency disclosures for improper employee surveillance purposes or to identify and harass whistleblowers are not sanctioned under Section (b)(1) of the Privacy Act.