RMAs and the Privacy Act

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This question is for those using a records management or document management application. Do you perform text-based document searches (including the capability of searching for individual names)in an RMA or DMA? Do you perform searches of metadata containing individual names (example: author, to, from, filed by)? Does your agency consider these information retrieval possibilities to mean that the RMA/DMA is a Privacy Act system of records since documents can be retrieved by name? Thanks.

Sherry Smith OCC Records Officer 202-874-5035

-- Anonymous, September 19, 2001

Answers

We can search by author when author name is an attribute in the metadata in our records management application--or in a document management system. We do not consider records to be a privacy system of records if our primary method of use or search is NOT by name or other personal identifier. (I.e., if the records were not or would not be arranged by name, social security number, or other personal identifier in paper, it is unlikely they would be a privacy system of records in electronic form.)

-- Anonymous, September 21, 2001

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