The Privacy Act of 1974: An Assessment. APPENDIX 4 TO The Report of The Privacy Protection Study Commission.. Propagation of Corrections


The Commission believes that the requirement that an agency take reasonable steps to assure the accuracy of any record prior to disseminating it should be extended to require that corrections and amendments of records be forwarded to sources and to previous internal agency recipients of the erroneous or incomplete information. [(f)] In addition, the suggested revisions in the current propagation of corrections requirement would make the requirement applicable whether the error is discovered by the individual or by the agency. To keep this from imposing an undue burden on the agencies, however, a correction resulting from a normal agency update would not have to be propagated, unless (a) sources or prior recipients could not otherwise be "reasonably expected" to become aware of it; and (b) it could be expected to affect the outcome of a determination about the individual by a source or prior recipient. In addition, only those sources or prior recipients who received or provided information within a reasonable period of time prior to the making of the correction would have to be notified, although an agency would be required to take "reasonable affirmative steps" to furnish the correction to any person named by the individual to whom the record in which it is made pertains. Finally, a source of erroneous information who was not acting in an official capacity as a representative, officer, employee, or agent of an agency or other organization need not be apprised of a correction.

The Commission believes it appropriate to place the basic responsibility for propagating corrections on the record-keeping agency because there is otherwise no practical way for an individual to protect himself against the spread of erroneous information about him throughout the Federal government.