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DPCLO Guidance

Defense Privacy Board Advisory Opinions


Published coupons and business return postcards are used as a means for an individual to request from the military service information concerning a particular recruiting program, and they usually contain blanks for the individual's name, address, telephone number, date and place of birth, level of education, degrees received, and the most recent previous educational agency or institution attended. If the coupon or postcard is used solely to fulfill the individual's request for information and then promptly is destroyed, the information is not entered into a system of records and a Privacy Act advisory statement is not required under 5 U.S.C. § 552a(e)(3)and DoD 5400.11–R

If any information about an individual is maintained in a system of records; i.e., kept and retrieved by an individual's personal identifier, then a Privacy Act advisory statement is required. The individual must be told the authority that permits the agency to collect the information, whether it is mandatory to provide the information, the purposes and routine uses of the information, and the effects, if any, on the individual for not providing the information. Also, if the Social Security number (SSN) is requested, the individual must be told the federal statute or executive order of the President that allows solicitation of the SSN, whether it is mandatory to provide it, and the uses to be made of it.

For both the SSN and the other information about the individual, it will be voluntary for the individual to provide them, and the effects of not providing either may result in a delay or inability in providing information to the individual. The SSN will be used to retrieve information about the individual and to verify the individual's identity. The remaining items of the Privacy Act advisory statement (authority, purposes, and routine uses) must be derived from the component's recruiting system of records notice as published in the Federal Register.