24.  WHAT CONSTITUTES A PRIVACY ACT REQUEST FOR ACCESS OR AMENDMENT FOR PURPOSES OF COMPLIANCE WITH PROCESSING AND REPORTING REQUIREMENTS

There is no requirement in the Privacy Act that a request specify or cite that law before it is to be processed or accounted for as a Privacy Act request. As a matter of policy, only requests which specify or clearly imply that they are being made under the Privacy Act receive the formal processing required by the law and implementing regulations and are reported as "Privacy Act requests." This avoids including routine record checks and requests to modify or update data elements in the annual Privacy Act report. This policy agrees with guidance issued by the Office of Management and Budget in Circular No. A–130, 50 Fed. Reg. 52730, 52739 (December 24,1985). However, this does not mean that requests not citing the Privacy Act should not be honored.