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Defense Privacy Board Advisory Opinions
NO REQUIREMENT TO PROVIDE PRIVACY ACT ADVISORY STATEMENTS TO LABOR ORGANIZATIONS
A labor organization may furnish information obtained from its members to a Department of Defense (DoD) component to facilitate allotment of union dues, even though the employee–union member is not given a Privacy Act advisory statement before providing the information to the labor organization.
The Privacy Act, 5 U.S.C. § 552a, does not apply to labor organizations; hence, they are not obligated to meet the subsection (e)(3) requirement to provide Privacy Act advice to federal employees before obtaining information for a voluntary allotment of union dues. Any use of the Privacy Act advisory statement by a labor organization is voluntary and may result from express agreement with a DoD component or as a spontaneous union practice. The Standard Form 1187 used to authorize allotments from pay is required by the employee's finance office and information provided on the form will become part of a system of records from which information is retrieved using personal identifiers. If the employee furnishes the completed form to the DoD component, a Privacy Act advisory statement must be provided to the employee by the component. If the labor organization furnishes the completed form to the DoD component, no Privacy Act advisory statement is required unless the component and the labor organization have agreed otherwise.