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Under what circumstances are the programs/systems/logs that we capture in monitoring Internet usage considered a System of Records and subject to all requirements of the Privacy Act?

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Under what circumstances are the programs/systems/logs that we capture in monitoring Internet usage considered a System of Records and subject to all requirements of the Privacy Act?

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A. The Department of Justice determined that a network/Internet monitoring/logging/audit system is a System of Records for Privacy Act considerations if the system has the capability of attributing data to a person (whether or not it is used for this purpose). See: Federal Register, published Dec 30, 1999, pages 73585-73586, under Privacy Act of 1974.

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