REPORT ON COSTS OF IMPLEMENTING THE PRIVACY ACT OF 1974

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84-00933R000300250006-8
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 6
• Document Creation Date: December 12, 2016
• Document Release Date: November 15, 2001
• Sequence Number: 6
• Publication Date: July 16, 1976
• Content Type: REPORT

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EXECUTIVE OFFICE OF THE PRESIDENT
JUL 16 1976-
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
REPLY TO
ATTN OF: ISD
SUBJECT: Report on Costs of Implementing the Privacy Act of 1974
Agency Privacy Act Points of Contact
? IAC/ADP Members
IAC/Telecommunications Members
Regional ADP Council Chairpersons
Attached for your information is a copy of a new reporting
requirement on Privacy Act Costs issued earlier this
week.
t~\.~\~-aas Z
Walter W. Haase
Deputy Associate Director
for Information Systems
STATINTL
STATINTL
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BULLETIN NO. TQ-1
July 13, 1976
SUBJECT: Report on Costs of Implementing the Privacy Act of
1974
1. Purpose. This Bulletin establishes procedures for a
one-time report on the cost of complying with the Privacy
Act of 1974 in order to permit an evaluation of the overall
costs and effects of the Act.
2. Reporting Instructions.
a. General consideration:
(1) Reports should consist of agencies' best
estimates of the costs of implementing the Act. Agencies
should not establish separate permanent cost reporting
systems to meet this reporting requirement.
(2) Many of the provisions of the Privacy Act
prescribe record-keeping practices which are not unique to
the Privacy Act. Therefore, only the incremental costs
incurred as a direct consequence of the Privacy Act should
be included in this report. For example, the workload
estimates and associated costs of granting access to records
should be based on the agency's estimate of the increase in
such activity due to the Act, not the total cost of granting
access to individuals under other agency procedures or the
Freedom of Information Act. (It is recognized that, for
many agencies, this can only be based on a rough estimate of
the level of activity which would have existed absent the
Privacy Act.)
(3) Where appropriate, the workload projections or
assumptions on which estimates are based should be
explained.
(4) If the agency expects annual recurring cost for
future years (FY 77 and after) to be materially different
from first year operating costs (e.g., because of workload
projections) it should base the report on projected first
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year operating costs and describe in an accompanying
narrative how later year costs can be expected to vary. See
paragraph d, below, regarding the period covered by this
report.
b. Content of the Report:.-- Provide estimates of start-
up (one-time) and operatin(recurring) costs for each of
the following:
(1) Publication requirements -- Report all costs
for the developmen?, publication, ancf distribution of rules,
notices, administrative procedures, revisions to agency
forms, notices to the public, and other publications
required under the Act.
(2) Training -- Report both the cost of developing
and conducting agency training (including training
materials) and costs associated with participation ' of
employees in training programs conducted by other central
agencies such as the Civil Service Commission.
(3) Granting access -- Report the net costs
associated iw th receiiv ng, recording, reviewing and
responding to requests for access to records as well as
appeals of denials of access. This element should include
only those costs directly attributable to activity under the
Privacy Act. Workload estimates for inquiries and requests
for access under the Privacy Act should be reduced by the
levels of similar activity which existed prior to the Act.
The development of any new procedures should be shown as
one-time costs.
(4) Correcting records -- Report the costs
with ith receivzn, recording, reviewing, and
responding to requests for correction of records including
appeals of denial of such requests. As above, only the cost
of additional activity directly attributable to the Privacy
Act should be included.
(5) Security and control -- Report the cost of
complying with tfie- requirements to establish appropriate
administrative and physical safeguards to protect the
security and integrity of agency records beyond those
otherwise necessary (e.g., for fiscal integrity, national
security, or continuity of agency operations). Include both
the costs of development or acquisition of hardware or
computer programs to monitor or control agency record-
keeping systems; costs for safeguarding files manually
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maintained in files, safes or other special storage areas;
and any other costs of developing and operating safeguards.
(6) Acco~un_t~ng for disclosures -- Report both the
initial and c`on iE'nuing costs associated with accounting for
disclosures. Include costs associated with development of
any special administrative procedures or modifications of
computer programs to permit maintenance of accounting
records. Also include costs associated with the compilation
and disclosure of accounting; records to individuals
exercising their rights under the Act.
(7) New data collection procedures -- Report the
direct costs; if any, incurred by the agency because of
limits imposed by the Act on the agency's ability to obtain
information; e.g., costs associated with the establishment
of new/separate data collection processes to seek
information directly from individuals rather than from other
agencies.
(8) All Other Costs -- Report any other costs
attributable to the Act and specify the purpose of each.
Such costs might include lost revenue from sale or rental of
mailing lists, cost of preparing reports on new systems and
the annual report, and the cost of any litigation including
costs or damages awarded in actions in which the plaintiff
prevailed.
(9) Reductions from Records/Systems eliminated --
Report the savings as a resuTtt of reports and systems
eliminated as a consequence of a review of systems subject
to the Act.
(10) Collections -- Report fees paid by individuals
for copies of their records as provided for in 5 U.S.C.
552a(d) (1) and (f) (5) .
c. Report Format -- A standard format for agency
reports mown as the Exhibit to this Bulletin. A single
agency summary is required for each agency although
subsidiary detailed reports for major record-keeping
subelements of the agency may be provided at the agency's
option. If supporting material includes extensive tabular
data, agencies should devise such formats as they deem
appropriate to present the material. No special format is
prescribed for any accompanying narrative which the agency
deems relevant.
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d. Reporting Period -- Start up costs will include any
one-time costs incurred from January 1, 1975 through
September 30, 1976. Operating costs should cover the period
September. 27, 1975 through September 30, 1976.
e. Distribution of the Report -- Provide two copies of
the report to tiie Office of Management and Budget (Attn:
Information Systems Division).
f. Timing -- Reports should be submitted to the office
of Management and Budget not later than August 31, 1976.
3. Inquiries. Inquiries may be addressed to the
Information Systems Division, OMB (395-4814 or IDS 103).
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PRIVACY ACT OF 1974
PART IV - INCREMENTAL COST OF IMPLEMENTATION
AGENCY _
BUREAU~(optional)
($ Outlays)
START UP*
OPERATING**
1. Publication Requirements
2. Training
3. Granting Access
4. Correcting Records
5. Security and Control
6. Accounting for Disclosures
7. New Data Collection Procedures
8. All Other Costs
9. Reductions from Records/Systems
Eliminated (deduct)
10. Collections (deduct)
TOTAL
* Start up costs will include any one-time costs incurred from
January 1, 1975 through September 30, 1976.
** Operating costs should cover the period September. 27, 1975
through September 30, 1976.
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