Why doesn the Department of Commerce just follow the OMB guidance and the Privacy Act requirements?
We do. However, as the Discussion section indicates, the DOC policy on Privacy Policy Statements and Information Collection is designed to meet the requirements of multiple enactments and executive directives. The policy combines all of these mandates into a single set of rules which cover most situations. If after reading the Discussion section of the policy you believe you need further guidance regarding the Privacy Act and Paperwork Reduction Act, you should contact your agency’s Privacy Officer or Paperwork Reduction Officer.