ACCOUNTING OF DISCLOSURES OF RECORDS MADE TO PERSONS OR ENTITIES OUTSIDE THE CENTRAL INTELLIGENCE AGENCY (CIA)

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84-00933R000400070006-7
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 6
• Document Creation Date: December 9, 2016
• Document Release Date: September 11, 2000
• Sequence Number: 6
• Publication Date: June 3, 1981
• Content Type: REPORT

*OGC Has Reviewed*
Approved For-Release 2001/09/03 : CIA-RDP84-009338000400070006-7
SUBJECT: Accounting of Disclosures of Records Made to Persons
or Entities Outside the Central Intelligence Agency
(CIA)
REFERENCE: Memo fm OGC dtd 26 May 81, same subject (OGC 31-04296)
1. The Office of Data Processing (OD?) maintains five systems
of records subject to the Privacy Act and reported in the Federal
Register. Contractual relationships with hardware and software
vendors providing services to CIA make it necessary for us to
disclose information contained in these systems to contractors'
representatives. ODP does not currently keep any purposeful or
complete accounting of these disclosures. To do so would entail an
unwarranted burden in carrying out legitimate administrative
correspondence with contractors for the reasons stated below.
2. ODP makes no disclosures outside of CIA from two of its
Privacy S3ystems, the ODP Training Records System and ODP's Computer
Access Files. The first of these systems is used to keep track of
the Agency-sponsored training completed by ODp employees. It is a
computerized ready-reference data base used for local administra-
tive functions in ODP. No disclosures outside of CIA are necessary
or proper because the Office of Training and Education maintains
the official record for each employee.
3. The second system, the Computer Access File, records the
User Identification (USERID) and Password of every person who has
access to an ODP computer through a terminal. This information is
used for CIA internal security management and is therefore not
disclosed outside CIA. STATINTL
4. Information concerning em to ees who are working or plan
to work for a contractor, e.a., etc. on an ODP
contract, is maintained in the ree remaining Privacy Systems.
The first of these, the Applications Tracking System, keeps track
of, among other things, the hours expended by staff or contractor
employees on an ODP project. This data base is used as an
authority file for charging ODP customers through a Project
Activity Report (PAR) for the man-hours expended on an ODP project
done for them. It is also used to verify the invoices of can-
tractors for billed man-hours. This verification frequently
requires a Contracting Officer's me
chnical Representative (COTR) to
discuss with a Contractor's Representative the contents of this
system of records regarding the hours reported by a contractor's
employee. Because there are several COTR's in ODP with authorized
access to the system, no accounting is kept of such disclosures.
Approved For Release 2001/09/03 : CIA-RDP84-00933R000400070006-7
 Approved FQLRelease 2001/09/03 : CIA-RDP84-00934R000400070006-7
To do so would require a single point of contact who would record
each disclosure in a manual or computer-based log. This would not
be inposs.ible, but it seems hardly warranted by the type of
disclosure concerned.
5. The second file from which disclosures are made to
contractors, again by COTR's and also by ODP's Security Officer and
Assssistant, is ODP's Security Clearance Records. This file keep..
track of the security clearances and compartmented accesses
requested, in process, or granted to contractor emtp_ployees.
Frequent dialogue occurs between ODP employees and contractors'
representatives about the status of clearances requested for
contractors' employees. Again, no accounting is kept of these
discussions. To gain the control necessary to do so would require
that the Security Officer be the single person authorized to
discuss clearances with contractors. Such a bottleneck would
hamper relations with contractors.
6. The third ODP file from which disclosures are made to
contractors, usually only by the Security officer or Assistant, is
OAP's Computer Room Access File. This file keeps track of which
e nployees, Agency and contractor, have been authorized to enter 01-)LJ
computer rooms. This information is used to request Special Badge
Indicators from the Office of Security and to provide the computer
centers with a list of authorized personnel. Contractors occa-
sionally want to know whether one of their employees has access to
a particular computer center. (This is true especially of computer
maintenance personnel.) ODP has not placed any restrictions on who
in 0D: can provide a contractor with this information. Such re-
triction would be prerequisite to establishing an accurate
accounting of this type of disclosure.
7. "o4thout a clear definition of what constitutes a
disclosure, ODP would find it difficult to decide what should be
accounted for. ODP has taken the view that the information being
discussed (disclosed) with contractors in the situations described
above is necessary to the proper conduct of contractual business
and therefore not subject to the accounting provisions of the
Privacy Act. ODP's line of reasoning .has been that the contractor,
through a, contractual relationship, with CIA, become an extension
of the Agency. Therefore, routine disclosures to contractor
employees do not require accounting under the Privacy Act.
STATINTL
O/D/ODP/ ee/3 June 1981
Distribution:
Orig - A/EO/DDA
2 - O/D/ODP
Approved For Release 2001/09/03 : CIA-RDP84-00933R000400070006-7
 Approved Fa elease 2001/09/03 : CIA-RDP84-0093&R000400070006-7
26 May 1981
MEMORANDUM FOR: See Distribution
FROM
STATINTL
SUBJECT
Office of General Counsel
Accounting Of Disclosures of Records
Made To Persons Or Entities Outside
The Central Intelligence Agency (CIA.)
1. To aid in a review of recordkeeping practices
relating to systems of records maintained by the Agency (as
defined under the Privacy Act), this Office needs to deter-
mine to what extent an accounting has been or is being
maintained for each disclosure of records made to persons
or entities outside the Central Intelligence Agency.
Accordingly, it is requested that you provide this Office
with a brief description of the system of accounting used
for such disclosures made from records systems under your
cognizance. If no such accounting has been or is being
maintained, then you should provide this Office with a
brief evaluation of what technical steps, manpower needs
and financial costs would be required to establish and
maintain such a system of accounting. (In drafting your
evaluation, assume the system of account will have to
accurately record: (1) the date, nature and purpose of
each such disclosure, and (2) the name and address of each
person. or entity to whom such. a disclosure is made. Use
your own professional judgment whether such a system of
accounting can or should be automated or manual.)
2. This Office would appreciate receiving a response
to this inquiry by no later than the close of business on 5
June 1981. Please feel free to call me (7521-black; 9336-
red; 8255-gray) if you have any questions about this
matter. STATINTL
Approved For Release 2001/09/03 : CIA-RDP84-00933R000400070006-7
 Approved Foelease 2001/09/03: CIA-RDP84-009:rR000400070006-7
General Counsel
Legislative Counsel
Inspector
General
Director
of
Personnel
Director
of
Equal Employment Opportunity
Director
of
Public Affairs
Executive
Assistant to the DCI
Executive
Secretary
Director
of
Central Reference
Director
of
Economic Research
Director
of
Geographic & Cartographic Research
Director
of
Communications
Director
of
Finance
Director
of
Logistics
Director
of
Medical Services
d"irector
of
Data Processing
Director
of
Security
Director
of
Training & Education
Director
of
Technical Service
Chief, Information & Privacy Division
Chief, Information Management Staff/DDO
Chief, Support Staff, Intelligence Community Staff
Administrative Officer, DCI Area
Chief, Career Management Staff/DDO
Career Management Officer/DDA
Personnel Officer/DDS&T
NFAC/FIO
Approved For Release 2001/09/03 : CIA-RDP84-00933R000400070006-7
 G 0GC 81-04296
d.Fo ase 2001/09/03: CIA-RDP84-009,3fl00400070006-7
26 May 1981
STATINTL
MEMORANDUM FOR: See Distribution
FROM
DP
SUBJECT Accounting Of Disclosures Of Records
Made To Persons Or Entities Outside
The Central Intelligence Agency (CIA)
1. To aid in a review of recordkeeping practices
relating to systems of records maintained by'the Agency (as
defined under the Privacy Act), this Office needs 'Co deter-
mine to what extent an accounting has been or is being
maintained for each disclosure of records made to persons
or entities outside the Central Intelligence Agency.
Accordingly, it is requested that you provide this Office
With a brief description of the system of accounting used
for such disclosures made from records systems under your
cognizance. If no such accounting has been or is being
maintained, then you should provide this Office with a
brief evaluation of what technical steps, manpower needs
and financial costs would be required to establish and
maintain such a system of accounting. (In drafting yrur
evaluation, assume the system of account will have to
accurately record: (1) the date, nature and purpose of
each such disclosure, and (2) the name and address of each
person or entity to whom such a disclosure is made. Use
your own professional judgment whether such a system of
accounting can or should be automated or manual.)
2. This Office would appreciate receiving a response
to this inquiry by no later than the close of business on 5
June 1981. Please feel free to call me (7521-black; 9336-
red; 8255-gray) if you have any questions about this
matter.
Approved For Release 2001/09/03 : CIA-RDP84-00933R000400070006-7
 STATI NT4
R .
~ TING AND RECORD SHEET
SUBJECT. Optional)
FR / i
L v
Esquire
EXTENSION
?521
NO.
OGC 81-042136
Office of General. Counsel
9336
DATE 26 May 1981
TO: (Officer designation, room number, and
building)
DATE
OFFICER'S
COMMENTS (Number each comment to show from whom
RECEIVED
FORWARDED
INITIALS
to whom. Draw a line across column after each comment.)
Director of Data Processi
Room 2D00 DX-6 GREEN
g
1 )
G?
PO~l
OOP
4.
ILLEGIB
5.
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FORM 610 USE VRtVIOUS
Ye EDITIONS
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