Records, Computers and the Rights of Citizens. Dimensions of the Problem

07/01/1973

A modern organization, as a rule, maintains elaborate records about the money it spends, the people it serves, the quantities of goods and services it dispenses, and the number, qualifications, and salaries of the people who work for it. It does so, in part, because it must account for its activities to investors or taxpayers, and to other organizations that monitor and regulate its behavior.

An organization also needs to plan for the future. A firm selling to the public is interested in knowing what the public wants, or can be persuaded to want. A school needs to know about the financial and intellectual capabilities of students coming to it for learning. A government agency tries to forecast demand for the services it provides or supports.

These incentives to develop indicators of institutional performance make it difficult to control the quantity and variety of personal data stored in administrative record-keeping systems, and the statistical-reporting and research uses that are made of such data. The personal data that organizations collect for administrative purposes should be limited, ideally, to data that are demonstrably relevant to decision making about individuals. A substantial amount of personal data, however, appear to be collected because at some point someone thought they might be "useful to have," and found they could be easily and cheaply obtained on an application form, or some other record of an administrative transaction.

For example, college students applying for governmentguaranteed loans in one State have been required to provide the State guarantee agency with data on matters that had no direct relation to its individual entitlement decisions. These data, "for our statistical interest" as their intended use was described to the Committee, included race, marital status, sex, adjusted family income, and student-reported "average grades received for last term of fulltime post-high school study." These data have been used to produce statistical reports for internal agency use, for informal discussions with State legislators, and to "run a profile once yearly on . . . schools and . . . lenders to see if there is any odd pattern . . . occurring." On one occasion data in the system also have been used in a study conducted by an outside researcher. For making entitlement decisions, however, the data being collected in excess of those required by law, were described to us as not very helpful to the program, and at least two data elements-sex and student-reported grades-were said to be absolutely valueless.1

The student loan case is but one illustration. The presentations of system managers and users yielded others. We found that decisions to collect personal data are being made without careful consideration of whether they will in fact serve the purposes for which they are supposedly being collected. As a result, substantial sums may be spent on comprehensive data collections for purposes that could often be much better served by other approaches, such as collecting statistical-reporting and research data only from a small sample of an organization's clients or beneficiaries. Most disturbing of all, we found that personal data in excess of those clearly needed for making decisions about individuals are sometimes collected in a way that makes them seem prerequisite to the granting of rights, benefits, or opportunities.