1 

18–10–02 

SYSTEM NAME: 

The Office of Inspector General Data Analytics System 

(ODAS). 

SECURITY CLASSIFICATION: 

None. 

SYSTEM LOCATION: 

The Office of Inspector General, Information 

Technology Audits and Computer Crimes Investigations 

(ITACCI), U.S. Department of Education, 550 12th Street, 

SW., room 8089, Washington, DC 20024–6122. 

CATEGORIES OF INDIVIDUALS COVERED BY THE SYSTEM: 

This system will include records on individuals that 

are obtained from the following other systems of records 

maintained by the Department: 

Education Central Automated Processing System (18–03–

02) – The categories of individuals included from this 

system are employees of the Department, consultants, 

contractors, grantees, advisory committee members, and 

other individuals receiving funds from the Department for 

performing services for the Department. 

Federal Student Aid Application File (18–11–01) - The 

categories of individuals included from this system are 
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students applying for Federal student financial assistance 

under Title IV of the Higher Education Act of 1965, as 

amended (HEA). 

Recipient Financial Management System (the Department 

soon expects to amend this system and re-name it as the 

Common Origination and Disbursement System (COD)) (18–11–

02) - The categories of individuals included from this 

system are records of individuals who apply for or receive 

a grant or loan which is made under (1) the Federal Pell 

Grant Program; (2) the Academic Competitiveness Grant (ACG) 

Program; (3) the National Science and Mathematics Access to 

Retain Talent Grant (National SMART Grant) Program; and (4) 

the William D. Ford Federal Direct Loan (Direct Loan) 

Program, Federal Direct Unsubsidized and Subsidized 

Stafford/Ford Loans, and Federal Direct PLUS Loans. 

Title IV Program Files (18–11–05) - The categories of 

individuals included from this system are: individuals who 

apply for Federal financial student aid; recipients of 

Federal Pell Grants; recipients of Federal Direct Student 

Loans; and borrowers whose loan defaulted or borrower died, 

became disabled or had a loan discharged in bankruptcy 

under the Federal Direct Student Loan program. 

National Student Loan Data System (NSLDS) (18–11–06)-

The categories of individuals included from this system 
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are: (1) Borrowers who have applied for and received loans 

under the William D. Ford Federal Direct Loan Program, the 

Federal Family Education Loan (FFEL) Program, the Federal 

Insured Student Loan (FISL) Program, and the Federal 

Perkins Loan Program (including National Defense Student 

Loans, National Direct Student Loans, Perkins Expanded 

Lending and Income Contingent Loans); and (2) Recipients of 

Federal Pell Grants and persons who owe an overpayment on a 

Federal Pell Grant, Federal Supplemental Educational 

Opportunity Grant or Federal Perkins Loans. 

Student Financial Assistance Collection Files (18–11–

07) - The categories of individuals included from this 

system are individuals who have student loans made under 

the FFEL Program: Stafford Loans (formerly the Guaranteed 

Student Loan Program (GSL), including Federally Insured 

Student Loans), Supplemental Loans for Students (SLS), PLUS 

Loans (formerly Parental Loans for Undergraduate Students), 

and Consolidation Loans; the William D. Ford Federal Direct 

Student Loan (Direct Loan) Program (formerly known as the 

Stafford/Ford Loan Program (SFLP), Federal Direct 

Unsubsidized Stafford/Ford Loan Program, Federal Direct 

Consolidation Loan, and Federal Direct Plus Loans; and 

Federal Perkins Loans (formerly known as National 

Direct/Defense Student Loans (NDSL)) and those who are 
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awarded grants under the Federal Pell Grant Program and the 

Supplemental Education Opportunity Grant Program (SEOG). 

Postsecondary Education Participants System (PEPS) 

(18–11–09) - The categories of individuals included from 

this system are owners (individuals, either solely or as 

partners, and corporate entities), officials, and 

authorized agents of postsecondary institutions; members of 

boards of directors or trustees of such institutions; 

employees of foreign entities that evaluate the quality of 

education; third-party servicers, including contact 

persons.

Department of Education (ED) PIN (Personal 

Identification Number) (18– 11–12) - The categories of 

individuals included from this system are former, current 

and prospective students and parents who apply for an ED 

PIN number. The ED PIN number is used for identification 

purposes when PII holders access other Department systems, 

including the Free Application for Federal Student Aid 

(FAFSA), Access America and the Direct Loan Program. 

Student Authentication Network Audit File (18–11–13) -

The categories of individuals included from this system are 

individuals who have had, or attempted to have, their 

identity verified for the purpose of electronically 

completing and signing promissory notes and other documents 
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in connection with applying for or obtaining aid, or 

carrying out other activities under the Student Financial 

Assistance Programs authorized by Title IV of the Higher 

Education Act of 1965, as amended. 

CATEGORIES OF RECORDS IN THE SYSTEM: 

This system will include records that are obtained 

from the following other systems of records maintained by 

the Department: 

Education’s Central Automated Processing System (18–

03–02) - The categories of records included from this 

system are individual’s name, address, social security 

number, eligibility codes, detailed and summary obligation 

data, reports of expenditures, and grant management data, 

including application and close out information. 

Federal Student Aid Application File (18–11–01) - The 

categories of records included from this system are the 

name, address, birth date, social security number, parents’ 

and students’ personal identification numbers assigned by 

the Department, and financial data necessary to identify 

applicants, verify applicant data, and calculate their 

expected family contributions for Federal student financial 

assistance. Also included from this system will be 

information on the student’s prior Federal Pell Grant 

awards and student loan status from the NSLDS database is 
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maintained in the system. Finally, included from this 

system will be information from an individual’s processed 

FAFSA form, such as Estimated Family Contribution, 

dependency status and post-secondary school identifier. 

Recipient Financial Management System (the Department 

expects to amend this system soon and re-name it as the 

Common Origination and Disbursement System (COD)) (18–11–

02) - The categories of records included from this system 

are records that are sent by institutions of higher 

education to the Department, and that include, but are not 

limited to, information such as an individual’s social 

security number, birth date, name, address, e-mail address, 

driver’s license number, telephone number, citizenship 

status, cost of attendance, enrollment information, type of 

financial aid award, and the amount and disbursement date 

of Federal financial aid awarded. In addition, this system 

contains collection referral amounts, loan repayment 

information, and promissory notes for loans made under the 

Federal Direct Loan program. 

Title IV Program Files (18–11–05) - The categories of 

records included from this system are records regarding the 

amount of Pell Grant received; an applicant’s demographic 

background; loan and education status; family income; 

social security number; address and telephone number; and 
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employment information on borrowers and co-signers; default 

claim number; amount of claim; information pertaining to 

locating a borrower; collection and repayment history; 

information pertaining to the amount of the loan and 

repayment obligation; forbearance; cancellation; 

disability; and deferment information; and personal 

identification numbers assigned by the Department. 

National Student Loan Data System (NSLDS) (18–11–06) -

The categories of records included from this system are 

records regarding: (1) Student/borrower identifier 

information including social security number, date of birth 

and name; (2) the information on borrowers’ loans covering 

the entire life cycle of a loan from origination through 

final payment, cancellation, discharge or other final 

disposition including details regarding each loan received 

by a student such as information on loan amounts, 

educational status, disbursements, balances, loan status, 

collections, claims, deferments, refunds and cancellations; 

(3) enrollment information including school(s) attended, 

anticipated completion date, enrollment status and 

effective dates; (4) student demographic information such 

as course of study, dependency, citizenship, gender, data 

on family income, expected family contribution, and 

address; (5) Federal Pell Grant amounts and dates; and (6) 
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Federal Pell Grant, Federal Supplemental Educational 

Opportunity Grant, and Federal Perkins Loan Program 

overpayments. 

Student Financial Assistance Collection Files (18–11–

07) - The categories of records included from this system 

are records regarding an applicant’s demographic 

background; loan, repayment history, and educational 

status; family income; social security number; address and 

telephone numbers; employment information on borrowers and 

co-signers; collection activity on accounts; default claim 

number; amount of claim; information pertaining to locating 

a borrower; collection and repayment obligation; 

forbearance; cancellation; disability; deferment; 

administrative wage garnishment; bankruptcy, death; closed 

school discharge; hearings; photocopy of all promissory 

notes; account collection records; administrative 

resolutions and litigations; and parents’ and students’ 

personal identification numbers assigned by the Department. 

Postsecondary Education Participants System (PEPS) 

(18–11–09) - The categories of records included from this 

system are records regarding the eligibility, 

administrative capability, and financial responsibility of 

postsecondary institutions that participate in the student 

financial aid programs, including the names, taxpayer 
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identification numbers (social security numbers), business 

addresses, and phone numbers of the individuals with 

substantial ownership interests in, or control over, those 

institutions, and personal identification numbers assigned 

by the Department. 

The Department of Education (ED) PIN (Personal 

Identification Number) Registration System (PIN) (18–11–12) 

- The categories of records included from this system are 

name, social security number, date of birth and address of 

prospective students and parents who apply for an ED PIN 

number. 

Student Authentication Network Audit File (18–11–13) -

The categories of records included from this system are 

related to individuals seeking to have their identity 

verified for the purpose of electronically completing and 

signing promissory notes and other documents in connection 

with applying for or obtaining aid. Records include the 

individual’s social security number; date of birth; first 

and last name; user code (i.e., the Department, lenders, 

schools, guarantee agencies and holders of Federal student 

loans) identifying the entity seeking to verify the 

individual’s identity; data provided by the user that may 

subsequently be used for auditing or other internal 

purposes of the user); an action code documenting the 
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“affirmed” or “denied” verification response the system 

receives from the Department’s PIN database; a unique 

identifier comprising a system-generated sequence number; 

and, the date and time the individual’s identity is 

authenticated against the Department’s PIN database. 

AUTHORITY FOR MAINTENANCE OF THE SYSTEM: 

The Inspector General Act of 1978, as amended, (5 

U.S.C. Appendix. 

PURPOSE(S): 

This system of records is maintained for purposes of: 

(1) Enabling the Office of Inspector General (OIG) to 

fulfill the requirements of section (4)(a)(1), (3), and (4) 

of the Inspector General Act of 1978, as amended, which 

require OIG to provide policy direction for and to conduct, 

supervise, and coordinate audits and investigations 

relating to the programs and operations of the Department; 

to conduct, supervise and coordinate activities for the 

purpose of promoting economy and efficiency in the 

administration of, or preventing and detecting fraud, and 

abuse in, the programs and operations of the Department; 

and to conduct, supervise, or coordinate relationships 

between other Federal, State, and local agencies with 

respect to matters relating to economy and efficiency, or 

the prevention and detection of fraud, and abuse in 
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programs and operations of the Department or the 

identification and prosecution of participants in such 

fraud, or abuse; (2) improving the efficiency, quality, and 

accuracy of existing data collected by the Department; (3) 

conducting data modeling for indications of fraud, waste, 

and abuse, and internal control weaknesses concerning 

Department programs and operations, the results of which 

may be used in the conduct of audits, investigations, 

inspections, or other activities as necessary to promote 

economy and efficiency and to prevent and detect fraud, 

waste, and abuse in Department programs and operations; and 

(4) coordinating relationships with other Federal, State, 

local, or foreign agencies or other public authorities 

responsible for assisting in the investigation, 

prosecution, oversight, or enforcement of violations of 

administrative, civil, or criminal law or regulations. 

ROUTINE USES OF RECORDS MAINTAINED IN THE SYSTEM, INCLUDING 

CATEGORIES OF USERS AND THE PURPOSES FOR SUCH USES: 

The Department may disclose information contained in a 

record in this system of records without the consent of the 

individual if the disclosure is compatible with the purpose 

for which the record was collected, under the following 

routine uses. OIG may make these disclosures on a case-bycase basis or, if OIG has met the requirements of the 
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Computer Matching and Privacy Protection Act of 1988, as 

amended, under a computer matching agreement. 

(1) Disclosure for Use by Other Law Enforcement 

Agencies. The Department may disclose information from this 

system of records as a routine use to any Federal, State, 

local, foreign agency, or other public authority 

responsible for enforcing, investigating, prosecuting, 

overseeing, or assisting in the enforcement, investigation, 

prosecution, or oversight of, violations of administrative, 

civil, or criminal law or regulation if that information is 

relevant to any enforcement, regulatory, investigative, 

prosecutorial, or oversight responsibility of the 

Department or of the receiving entity.

(2) Disclosure to Public and Private Entities to 

Obtain Information Relevant to Department of Education 

Functions and Duties. The Department may disclose 

information from this system of records as a routine use to 

public or private sources to the extent necessary to obtain 

information from those sources relevant to an OIG 

investigation, audit, inspection, or other inquiry. 

(3) Disclosure for Use in Employment, Employee 

Benefit, Security Clearance, and Contracting Decisions. 

(a) For Decisions by the Department. The Department 

may disclose information from this system of records as a 
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routine use to a Federal, State, local, or foreign agency 

maintaining civil, criminal, or other relevant enforcement 

or other pertinent records, or to another public authority 

or professional organization, if necessary to obtain 

information relevant to a Department decision concerning 

the hiring or retention of an employee or other personnel 

action, the issuance or retention of a security clearance, 

the letting of a contract, or the issuance or retention of 

a license, grant, or other benefit.

(b) For Decisions by Other Public Agencies and 

Professional Organizations. The Department may disclose 

information from this system of records as a routine use to 

a Federal, State, local, or foreign agency, other public 

authority, or professional organization in connection with 

the hiring or retention of an employee or other personnel 

action, the issuance or retention of a security clearance, 

the letting of a contract, or the issuance or retention of 

a license, grant, or other benefit. 

(4) Disclosure to Public and Private Sources in 

Connection with the Higher Education Act of 1965, as 

Amended (HEA). The Department may disclose information from 

this system of records as a routine use to facilitate 

compliance with program requirements to any accrediting 

agency that is or was recognized by the Secretary of 
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Education pursuant to the HEA; to any educational 

institution or school that is or was a party to an 

agreement with the Secretary of Education pursuant to the 

HEA; to any guaranty agency that is or was a party to an 

agreement with the Secretary of Education pursuant to the 

HEA; or to any agency that is or was charged with licensing 

or legally authorizing the operation of any educational 

institution or school that was eligible, is currently 

eligible, or may become eligible to participate in any 

program of Federal student assistance authorized by the 

HEA. 

(5) Litigation and Alternative Dispute Resolution 

(ADR) Disclosures. 

(a) Disclosure to the Department of Justice. If the 

disclosure of certain records to the Department of Justice 

(DOJ) is relevant and necessary to litigation or ADR and is 

compatible with the purpose for which the records were 

collected, the Department may disclose those records as a 

routine use to the DOJ. The Department may make such a 

disclosure in the event that one of the following parties 

is involved in the litigation or ADR or has an interest in 

the litigation or ADR: 

(i) The Department or any component of the Department; 
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(ii) Any employee of the Department in his or her 

official capacity; 

(iii) Any Department employee in his or her individual 

capacity if the DOJ has been asked or has agreed to provide 

or arrange for representation for the employee; 

(iv) Any employee of the Department in his or her 

individual capacity if the Department has agreed to 

represent the employee or in connection with a request for 

that representation; or 

(v) The United States, if the Department determines 

that the litigation or ADR proceeding is likely to affect 

the Department or any of its components. 

(b) Other Litigation or ADR Disclosure. If disclosure 

of certain records to a court, adjudicative body before 

which the Department is authorized to appear, individual or 

entity designated by the Department or otherwise empowered 

to resolve disputes, counsel, or other representative, 

party, or potential witness is relevant and necessary to 

litigation or ADR and is compatible with the purpose for 

which the records were collected, the Department may 

disclose those records as a routine use to the court, 

adjudicative body, individual or entity, counsel or other 

representative, party, or potential witness. The Department 

may make such a disclosure in the event that one of the 
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following parties is involved in the litigation or ADR or 

has an interest in the litigation or ADR: 

(i) The Department or any component of the Department; 

(ii) Any employee of the Department in his or her 

official capacity; 

(iii) Any Department employee in his or her individual 

capacity if the DOJ has been asked or has agreed to provide 

or arrange for representation for the employee; 

(iv) Any employee of the Department in his or her 

individual capacity if the Department has agreed to 

represent the employee; or 

(v) The United States, if the Department determines 

that the litigation or ADR is likely to affect the 

Department or any of its components. 

(6) Disclosure to Contractors and Consultants. The 

Department may disclose information from this system of 

records as a routine use to the employees of any entity or 

individual with whom or with which the Department contracts 

for the purpose of performing any functions or analyses 

that facilitate or are relevant to an OIG investigation, 

audit, inspection, or other inquiry. Before entering into 

such a contract, the Department must require the contractor 

to maintain Privacy Act safeguards, as required under 5 

U.S.C. 552a(m) with respect to the records in the system. 
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(7) Debarment and Suspension Disclosure. The 

Department may disclose information from this system of 

records as a routine use to another Federal agency 

considering suspension or debarment action if the 

information is relevant to the suspension or debarment 

action. The Department also may disclose information to any 

Federal, State, or local agency to gain information in 

support of the Department’s own debarment and suspension 

actions. 

(8) Disclosure to the Department of Justice. The 

Department may disclose information from this system of 

records as a routine use to the DOJ to the extent necessary 

for obtaining the DOJ’s advice on any matter relevant to 

Department of Education programs or operations. 

(9) Congressional Member Disclosure. The Department 

may disclose information from this system of records to a 

Member of Congress or to a congressional staff member in 

response to an inquiry from the congressional office made 

at the written request of the constituent about whom the 

record is maintained. The member’s right to the information 

is no greater than the right of the individual who 

requested the inquiry. 

(10) Benefit Program Disclosure. The Department may 

disclose records as a routine use to any Federal, State, 
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local, or foreign agency, or other public authority, if 

relevant to the prevention or detection of fraud and abuse 

in benefit programs administered by any agency or public 

authority. 

(11) Collection of Debts and Overpayment Disclosure. 

The Department may disclose records as a routine use to any 

Federal, State, local, or foreign agency, or other public 

authority, if relevant to the collection of debts or to 

overpayments owed to any agency or public authority. 

(12) Disclosure to the Council of Inspectors General 

for Integrity and Efficiency (CIGIE). The Department may 

disclose records as a routine use to members and employees 

of the CIGIE, or any successor entity, for the preparation 

of reports to the President and Congress on the activities 

of the Inspectors General.

(13) Disclosure for Qualitative Assessment Reviews. 

The Department may disclose records as a routine use to 

members of the PCIE, the DOJ, the U.S. Marshals Service, or 

any Federal agency for the purpose of conducting 

qualitative assessment reviews of the investigative or 

audit operations of the Department’s OIG to ensure that 

adequate internal safeguards and management procedures are 

maintained. 
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(14) Disclosure in the Course of Responding to Breach 

of Data. The Department may disclose records to appropriate 

agencies, entities, and persons when (a) it is suspected or 

confirmed that the security or confidentiality of 

information in this system has been compromised; (b) the 

Department has determined that as a result of the suspected 

or confirmed compromise there is a risk of harm to economic 

or property interests, identity theft or fraud, or harm to 

the security or integrity of this system or other systems 

or programs (whether maintained by the Department or by 

another agency or entity) that rely upon the compromised 

information; and, (c) the disclosure is made to such 

agencies, entities, and persons who are reasonably 

necessary to assist the Department in responding to the 

suspected or confirmed compromise and in helping the 

Department prevent, minimize, or remedy such harm. 

DISCLOSURE TO CONSUMER REPORTING AGENCIES: 

Not applicable to this system of records. 

POLICIES AND PRACTICES FOR STORING, RETRIEVING, ACCESSING, 

RETAINING, AND DISCLOSING OF RECORDS IN THE SYSTEM: 

STORAGE: 

The records are maintained on encrypted magnetic disks 

and encrypted tape cartridges in a locked computer facility 

within the U.S. Department of Education’s OIG. 
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RETRIEVABILITY: 

Records in this system of records are retrieved by 

name or other identifying information of an individual or 

institution. 

SAFEGUARDS: 

 Access to data in ODAS is restricted to authorized 

users and is recorded in an access log. All physical access 

to the Department’s site where this system of records is 

maintained is controlled and monitored by security 

personnel who check each individual entering the building 

for his or her employee or visitor badge. All data 

maintained in the system of records are kept on a secured 

and restricted private network and stored in a combination 

locked computer laboratory. ODAS is housed within a secure 

and controlled computer lab. Physical access to the lab is 

by authorized OIG personnel only. The general public does 

not have access to ODAS. 

All information stored in this system is secured by 

using database encryption technology and is resistant to 

tampering and circumvention by unauthorized users. Access 

to data by all users will be monitored using both automated 

and manual controls. The information is accessed by users 

either on a ‘‘need to know’’ and intended systems usage 
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basis or pursuant to a published routine use and consistent 

with the purposes of the system.

OIG maintains ODAS in a secure and controlled 

facility. Access to the computer lab is by authorized OIG 

personnel only. The general public does not have access to 

ODAS. The information maintained in ODAS is secured in 

accordance with OMB M– 03–22, OMB Guidance for Implementing 

the Privacy Provisions of the E-Government Act of 2002, 

September 26, 2003, the E-Government Act, Section 208, 

Attachment A, and NIST 800–53, Revision 1, Recommended 

Security Controls for Federal Information Systems, December 

2006. 

Contractors will not maintain this system, but under 

certain limited circumstances they may have access to the 

system. In accordance with the Department’s Administrative 

Communications System Directive OM: 5–101 entitled 

“Contractor Employee Personnel Security Screenings,” all 

Department personnel who have facility access and system 

access must undergo a security clearance investigation. 

Individuals requiring access to Privacy Act data are 

required to hold, at a minimum, a moderate-risk security 

clearance level. These individuals are required to undergo 

periodic screening at five-year intervals. 
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In addition to conducting security clearances, 

individuals with access to this system are required to 

complete security awareness training on an annual basis. 

Annual security awareness training is required to ensure 

that users are appropriately trained in safeguarding 

Privacy Act data in accordance with OMB Circular No. A– 

130, Appendix III. 

The computer system employed by the Department offers 

a high degree of resistance to tampering and circumvention. 

All users of this system of records are given a unique user 

identification, and users are required to change their 

password at least every 90 days in accordance with the 

Department’s information technology standards. 

RETENTION AND DISPOSAL: 

Records are maintained and disposed of in accordance 

with the Department’s Records Disposition Schedules 

applicable to the aforementioned records. A new records 

retention and disposition schedule is under development for 

this system of records. Until NARA approves a retention and 

disposition schedule for these records, The Department will 

not destroy any records. 

SYSTEM MANAGER AND ADDRESS: 
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Director, Computer Assisted Assessment Techniques, 

Information Technology Audits and Computer Crimes 

Investigations, Department of Education, Office of 

Inspector General, 400 Maryland Avenue SW., PCP, 

Washington, DC 20202–1510. 

NOTIFICATION PROCEDURE: 

This system is exempt from the notification procedures 

in 5 U.S.C. 552a(e)(4)(G) pursuant to 5 U.S.C. 552a(k)(2) 

and 34 CFR 5b.11(c)(1). 

RECORD ACCESS PROCEDURE: 

This system is exempt from the record access 

procedures in 5 U.S.C. 552a(e)(4)(H) pursuant to 5 U.S.C. 

552a(k)(2) and 34 CFR 5b.11(c)(1). 

CONTESTING RECORD PROCEDURE: 

This system is exempt from the contesting record 

procedures in 5 U.S.C. 552a(e)(4)(H) pursuant to 5 U.S.C. 

552a(k)(2) and 34 CFR 5b.11(c)(1). 

RECORD SOURCE CATEGORIES: 

This system contains records taken from the following 

Department systems: Education’s Central Automated 

Processing System (EDCAPS) (System Number 18–03–02); 

Federal Student Aid Application File (System Number 18– 11–

01); Recipient Financial Management System (the Department 
24

expects to amend this system soon and re-name it as the 

Common Origination and Disbursement System (COD)) (System 

Number 18–11–02); Title IV Program Files (System Number 18–

11– 05); National Student Loan Data System (NSLDS) (System 

Number 18–11–06); Student Financial Assistance Collection 

Files (System Number 18–11–07); Postsecondary Education 

Participants System (PEPS) (System Number 18–11– 09); The 

Department of Education (ED) PIN (Personal Identification 

Number) Registration System (System Number 18–11–12); and 

the Student Authentication Network Audit File (System 

Number 18–11–13). 

EXEMPTIONS CLAIMED FOR THE SYSTEM: 

Pursuant to 5 U.S.C. 552a(k)(2), the Secretary, 

through rulemaking, may exempt from a limited number of 

Privacy Act requirements a system of records that contains 

investigatory materials compiled for law enforcement 

purposes. The materials in this system fall within the 

scope of section 552a(k)(2) because they are investigatory 

materials compiled for purposes of enforcing Federal legal 

requirements. Therefore, the Secretary has issued final 

regulations published elsewhere in this issue of the 

Federal Register exempting the ODAS from the following 

Privacy Act requirements: 
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5 U.S.C. 552a(c)(3)—access to accounting of 

disclosure. 

5 U.S.C. 552a(c)(4)—notification to outside parties 

and agencies of correction or notation of dispute made in 

accordance with 5 U.S.C. 552a(d). 

5 U.S.C. 552a(d)(1) through (4) and (f)—procedures for 

notification or access to, and correction or amendment of, 

records. 

5 U.S.C. 552a(e)(1)—maintenance of only relevant and 

necessary information. 

5 U.S.C. 552a(e)(4)(G) and (H)— inclusion of 

information in the system of records notice regarding 

Department procedures on notification of, access to, 

correction of, or amendment of records.