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Guidance on Privacy Act Implications of "Call Detail" Programs

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Citation Edit

Office of Management and Budget, Guidance on Privacy Act Implications of 'Call Detail' Programs to Manage Employees' Use of the Government's Telecommunications Systems, 52 Fed. Reg. 12990 (Apr. 20, 1987) (full-text).

Overview Edit

The Office of Management and Budget developed 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 services.

This guidance:

  • 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 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 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.

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