LETTER TO THE HONORABLE JOHN S. D. EISENHOWER FROM LAWRENCE R. HOUSTON

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP80B01495R000200110021-8
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 5
• Document Creation Date: December 20, 2016
• Document Release Date: October 16, 2006
• Sequence Number: 21
• Publication Date: February 21, 1973
• Content Type: LETTER

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CENTRAL INTELLIGENCE. AGENCY
WASHINGTON, D.C. 20505
21 February 1973
i
The Honorable John S. D. Eisenhower
Chairman, Interagency Classification
Review Committee
The WhiteHouse
Washington, D. C.
OGC 73-0287
By letter of 23 January, Dave Young has distributed your
Letter of Instructions on the data index system for classified docu-
ments. Unfortunately, the Instructions pose very serious problems
for this Agency, and probably for others, which I believe need further
consideration and some action, discussed in the following paragraphs.
We comment on several other features also. To some degree we
repeat here some of our earlier comments to Mr. Tufaro concerning
an earlier draft.
The major problem to CIA is that the Instructions (para-
graph 6) would require us to include in our data index system docu-
ments in far greater number (several millions annually) than we are
equipped to do, namely, all exempt Confidential and Secret documents
and all Top Secret documents. It is virtually certain that we cannot
comply with the requirement in the time now available and it is cer-
tain that we cannot do so at all without substantial expenditures for
new equipment and hardware and corresponding substantial increases
in personnel and in salary costs. We do not now have funds or per-
sonnel available for this purpose.
Moreover, we cannot realistically argue in support of an
appropriation request, or otherwise, that there would be a benefit
to the government in any way commensurate with the increase in
costs. The CIA documents which have substantive or historical
value, by and large, are finished intelligence documents, which we
do index. Thus, for the purpose of preserving documents of value,
which is ;an objective of the NSC Directive, and based on cost factors,
finished intelligence documents are the ones which should go into the
data index system.
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The broadly stated requirement is particularly troublesome
because it comes as a surprise and at a late date. During the vari-
ous!meetings and discussions of the data index working group, ever
since the Directive was issued, the CIA representative consistently
has indicated that we do index finished intelligence documents and
are prepared to continue to do so under the NSC Directive. At the
December meetin eported to the full ICRC the CIA
practice in this regard and in ecember we so informed Mr. Tufaro.
when we commented on an earlier draft of the proposed Instructions.
I understand the proposed Instructions in December were our first
indication that we should include any documents additional to finished
intelligence documents.
You will recall also that although the Directive provides that
departments are to index selected categories of documents "approved
by the Interagency Classification Review Committee as having suffi-
cient historical or other value appropriate for preservation" the Com-
mittee has not addressed itself to this issue.
There are several somewhat less fundamental difficulties with
that portion of the Instructions which specifies the documents to be
included (paragraph 6). For example, the Letter was distributed in
late January 1973, but it requires the departments to submit to the
ICRC prior to 31 December 1972 selected categories of documents for
approval by the Committee. Further, although paragraph 6 acknowl-
edges that under the Directive categories of documents to be indexed
are to be approved by the Committee, this acknowledgment contradicts
the earlier, provisions in the same paragraph which in themselves
specify the', documents which must be indexed.
The. foregoing is directed specifically to the problems faced
by this Agency, but it seems likely the various departments may
have similar or other difficulties which the Committee should con-
sider. It is my suggestion that paragraph 6 be rescinded promptly
pending consideration by the Committee itself.
As to one of the data elements called for (by the Directive and
paragraph 7D of your Letter) -- the addressees of documents - we
have in being address lists, which include numbers of documents per
addressee for the indexed documents. Thus, we are able to trace the
movement of all copies of all indexed documents, although in realistic
terms the tracing would not be instantaneous and if it were directed
r r, 4 r
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to all indexed documents of a given year or any other large quantity
of 'documents, would not be inexpensive. This facility appears to
fit the requirements of the Directive and the Instructions. If on the
other hand we were to be required to revise our system so that a
print-out would show the number of copies or if each retrieved copy
had to show the actual distribution list, we would have serious prob-
lems. The index record of our system was expanded to its full
capacity late last year by the addition of several characters to iden-
tify the exemption categories of the Executive Order. To add even
the few characters required to include the number of copies would
force us to choose among abandoning or shortening other data ele-
ments which we have incorporated for other purposes (or shortening
the field length of a data element), expanding our data index record
at considerable cost or establishing what would amount to a parallel
system - the existing one would continue to be used for the purposes
of document retrieval, the new one would be designed specifically as
a mechanism to trace the movement and location of each copy of each
classified document. The latter choice would be exceedingly expen-
sive and in this day of the Xerox, would seem to be of little real value
in tracing unauthorized disclosures. We could study the implications
of these various choices and of course we will have to do so if it devel-
ops that our index as presently established cannot perform functions
which the Directive requires of it. In that event it would be appropri-
ate to consider requesting relief from that feature of the Directive.
A similar situation exists with respect to another specified
data element - the identity of the classifier. Under our procedures,
the identity of the classifier may be easily determined from the out-
put of our document index system used in conjunction with the output
of other computer and record systems in the Agency. This also is
consistent with the Directive and its objectives and I would hope the
Instructions do not intend a different arrangement.
The specifics and the features of the data index system and
how it is to work (primarily paragraph 7 of the Letter) may pose
some additional problems, but I assume these can be resolved upon
consideration by ICRC and on the basis of experience. Additionally,
one or two items are called for by the Instructions which the Directive
does not require -- the Originating Office, the Title or Description of
the document and automatic declassification on the basis of an event
or specified date. You may want to delete these as requirements.
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The reports required or contemplated in paragraphs 11 and 12
are some time away and we defer comment on them.
The CIA data index system has been in being for some time
ancl~is a highly sophisticated and effective mechanism. Some changes
have been made, consistent with our comments above, which have
brought it into line with the requirements of the Directive. I am
advised that other departments are nowhere near as advanced as is
this one, so it may be that others will have even more difficulty in
meeting the specifics of your Letter. For these reasons I would
hope that all concerned, including departments not represented on
ICR C, could regard the Letter of Instructions, modified as suggested
above, as tentative guidelines only. It might be well to advise all
departments to that effect. All this suggests that the matter of the
data index requirements is so complicated and far-reaching that it
would be useful to schedule the subject for thorough consideration
by an ICRC meeting.
Lawrence R. Houston
General Counsel
cc: Members of ICRC
Mr. Richard C. Tufaro
OGC:RHL:sin
Original
- Addressee
1
- SA/Information Control
1
- D/CRS'
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