COMMENTS ON OMB VERSION OF H.R. 12206

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP76M00527R000700140066-7
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 2
• Document Creation Date: December 12, 2016
• Document Release Date: November 21, 2001
• Sequence Number: 66
• Publication Date: July 18, 1974
• Content Type: MF

Approved For Release NIJOt0 CIA= 06A27RQ00700140066-7
18 JUL 1974
MEMORANDUM FOR: Legislative Counsel
ATTENTION STATINTL
SUBJECT : Comments on OMB Version of H. R. 12206
1. The Agency exemption contained in (f) (2) eliminates most of the
problems raised by the bill's original language. It is to be hoped that the
Congress will buy it, although the total exemption in the original OMB draft
would have been more desirable from the CIA viewpoint.
2. It would be advantageous to the Agency if the Committee report
made it clear that the bill's "publicity" provisions do not apply to systems
which, although they might incidentally contain records on some U. S. citizens
and/or resident aliens, consist almost exclusively of records on foreign
nationals. This would then exclude the CRS positive intelligence biographic
files and the ISG central counterintelligence index -- the largest biographic
files in the Agency. It should be possible to sell this idea.
3. As I understand the bill, the Agency would be required to:
a. publish annually in the Federal Register a notice concern-
ing each system of records maintained on U. S. citizens
and/or resident aliens, including the information elements
listed under (b) (1);
b. limit access to records on U. S. citizens and/or resident
aliens to those Agency employees with a need to know;
c. abstain from maintaining data on the politics or religion
of any U. S. citizen and/or resident alien; and
d. contribute data on the number of records in each exempted
system for inclusion in the President's annual report (un-
less this requirement was dropped in the final version).
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4. If (g) has been left in the bill, the DCI could, by publishing notifi-
cation of his written determination in the Federal Register, exempt the
Agency's personnel, applicant, security, and medical files from the (b) (1)
requirement that information on each system be published annually in the
Federal Register. I understand, however, that this was probably deleted
in the Committee staff's final version.
5. It occurs to me that it could be argued that portions of (b) (1) are
in conflict with the CIA Act of 1949. (B) calls for the publication of an official
title, and the figures required by (B) could, for some systems, provide clues
as to the total number of personnel employed by the Agency. These are rather
trivial considerations, however, and do not warrant making an issue of them.
6. If Agency applicants are still required to state whether they hold,
or have held, membership in any of a list of subversive organizations -- some
of which could be characterized as "political" -- this may technically be in
violation of (d) (4).
7. On the whole, the Agency can live with this bill very easily. The
demands placed upon the organization might be regarded as nuisances, but
they will not jeopardize our sources and methods or represent major work-
loads.
STATINTL
Chief, Classification Programs Branch
Information Systems Analysis Staff
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