Defense Privacy Board Advisory Opinions
28. THE PRIVACY ACT DOES NOT APPLY TO FILES INDEXED BY NONPERSONAL
IDENTIFIERS AND RETRIEVED BY MEMORY
Labeling of files by nonpersonal identifiers makes access
requirements of the Privacy Act inapplicable unless such files
actually are retrieved on the basis of an individual identifier
through a crossreference system or some other method. The
human memory alone does not constitute a crossreference system.
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