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DPCLO Guidance

Defense Privacy Board Advisory Opinions

THE PRIVACY ACT DOES NOT APPLY TO FILES INDEXED BY NON PERSONAL IDENTIFIERS AND RETRIEVED BY MEMORY

Labeling of files by non personal identifiers makes access requirements of the Privacy Act inapplicable unless such files actually are retrieved on the basis of an individual identifier through a cross reference system or some other method. The human memory alone does not constitute a cross reference system.