Comment Submitted by Andrew M. Strojny

DHS seeks to exempt certain systems of records from subsection (e)(1) of the Privacy Act. However, DHS provides no rationale for its position that the ?interests of effective law enforcement? requires that information be kept in an individual?s files even though ?the accuracy of the information obtained or introduced my be unclear, or the information my not be strictly relevant.? In fact, quite the opposite appears to be true. Effective law enforcement requires accurate and relevant information on individuals be kept. Inaccurate and irrelevant information encourages law enforcement to proceed on faulty information, go off on tangents, and perhaps falsely target innocent individuals. How inaccurate and irrelevant information may aid in establishing patterns of unlawful activity as DHS maintains is not self evident. In fact, inaccurate and irrelevant information would appear to impede, not help, in the establishment of such patterns. Inaccurate information and irrelevant information kept on individuals in a system of records can work to bring those individuals under false suspicion and could lead to other far reaching harmful consequences dependent on who has access to the system. It is because of these dangers that the Privacy Act was enacted in the first place. Absent some kind of concrete justifications or, at a minimum, examples illustrating why this action should be taken, there does not appear to be any reason for this exemption. It would appear to lead to less effective law enforcement and have potentially far reaching deleterious effects on the individuals who are the subjects of inaccurate and irrelevant information.