Comment Submitted by Anonymous

This rules proposal is flawed on many counts, of which I list 4. 1) Document safeguards: Data being retained has restricted access for those with a "need to know". The list of potential interested parties, however, includes the press, foreign governments, prospective employers, students, contractors, etc. This provides very few practical limits on its dissemination, and on privacy matters. 2) Data retention: 15 years is an inordinate amount of time to keep records on U.S. citizens who have committed no crime, nor have been accused of committing a crime. The wide access to such data (see (1)) is excessively intrusive into a citizen's privacy. At what point does such surveillance become unreasonable searching? 3) Constitution: There is no Constitutional basis for the policies defined in this document. Refer to U.S. Constitution, Art. 1, Sec. 8, for a list of the duties of the Federal Government. In relation to U.S. citizens, the proposed rules do not remotely resemble one of these permissible duties. 4) Privacy: Strong justification should be required to exempt any data from the 1974 privacy act, and the proposed ruling falls far short of such justification. Further, attempts to provide less privacy protections than are granted by existing law reflects _very_ poorly on the motivations for keeping such an over-reaching database. If you want to keep such information, why are you afraid of letting people know its uses? I was brought up under the teachings that the Soviet Union was evil, and justification for such accusations was that the Soviet Union watched its citizens in a similar way to the DHS seeks to do today. The attacks of 11 Sep, 2001, accomplished far more than could have ever been dreamed by Mr. bin Laden - he has succeeded in destroying the United States by turning it from a free society into one which is becoming increasingly paranoid and watched by the government. The Soviet Union was criticized as all citizens had to carry their "papers" to travel. At what point will it be necessary for a person to carry their papers to travel in the United States? Today, it seems, as each driver's license, which is a functional requirement to normal life, is now linked to one of many government databases, and all travel is watched and recorded. Rules such as this, which track each person's movement, and with such information stored for decades, are truly frightful. Thank you for hearing my position, comrade.