Many federal workers are simply unaware of the accounting requirement. Another problem with audit trails is that there is apparently little demand for them from record subjects. Ask around your agency and see if you don't get blank stares. Public data included The accounting requirement applies even when an agency discloses a wholly public record, such as an agency telephone book. Increasingly, agencies allow the public to use telephone books and similar resources on the Internet.
Ethics reports and other similar filings are also public.
Nevertheless, agencies that put public comments and docket information online in searchable form may be making disclosures from a system of records. If it does, then we have a mess. First, agencies commonly allow the public to use online resources without any registration. But if an accounting is required, then both the public and the agency would be burdened with collection of information of little interest. Besides, many Net users are annoyed when asked for personal information as a condition of access.