When do you need a PAS?
When you request an individual to furnish personal information (name, date of birth, social security number, etc) for a system of records, regardless of the method used to collect the information (i.e., forms, personal or telephonic interview, etc).
Note: If the information requested will not be included in a system of records, a PAS is not required.
How do you write a PAS?
The general format for a PAS is AUTHORITY; PURPOSE; ROUTINE USES; AND DISCLOSURE.
First, identify the PA systems notice where you are going to store the information. If you need assistance, contact the DoDIG Privacy Office.
Second, using information from the systems notice fill in the following areas: AUTHORITY AND PURPOSE. Under Authority, list the Federal law or Executive Order that appears in the systems notice (i.e., 5 U.S.C. 301, Departmental Regulations and Executive Order 9397 (SSN). Under Purpose, copy the same information that is contained in the systems notice under "Purpose."
Third, under ROUTINE USES address who in/outside the organization will have access to the information (i.e., used by the security office to annotate that training has been accomplished). Do not cite "Blanket Routine Uses apply."
Fourth, under DISCLOSURE cite whether or not the disclosure of information is "Voluntary" or "Mandatory". It is only appropriate to cite "Mandatory" when a Federal Law or E.O. of the President specifically imposes a requirement to furnish the information and provides a penalty for failure to do so. If furnishing information is a condition for granting a benefit or privilege voluntarily sought by the individual, it is voluntary for the individual to give the information.
In view of the above, most statements read as follows: DISCLOSURE: Voluntary. However, failure to provide the requested information may result in ______________(i.e., you not being considered for the position; not being notified in case of emergency; etc). |
All Privacy Act system of records notice actions are transmitted electronically to the DoDIG Privacy Office, the Defense Privacy Office and the Federal Register, since this method is both time and cost effective. Since the Defense Privacy Office uses special software to transmit the text to the Federal Register, please do not indent, underline, bold, double-space or center the text.
All new or amended systems require a "Narrative Statement" and a "System Notice." Click on the links above to access the formats.
Please prepare your text and the Narrative Statement using Microsoft Word and submit it electronically to the DoD IG Privacy Office.
Prior to designing a new system, however, we highly recommend that you contact the DoDIG Privacy Office to discuss the matter.
It takes approximately 120 days to establish a new system, which includes approval by DoD and Congress and publication in the Federal Register.
You can view the DoD IG PA systems of records notices on this site under System Notices. You may view the Government-wide systems and DoD and its components' systems on the Defense Privacy Office website.
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Does the PAS have to appear on the form?
Yes or on a separate form that can be retained by the individual collecting the information. If the information is collected by means other than a form completed by the individual (i.e., solicited over the telephone), a PAS should be read to the individual and if requested by the individual, a copy sent to him/her.
When forms are used to collect information about individuals for a system of records, the PAS shall appear as follows (listed in order of preference):
(1) Immediately below the title of the form;
(2) Elsewhere on the front page of the form (clearly indicating it is the PAS).
(3) On the back of the form with a notation of its location before the title of the form, or
(4) On a separate form which the individual may keep.
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