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60 Geo. Wash. L. Rev. 1509 (1991-1992)
Increased Invulnerability of Incorrect Records Maintained by Law Enforcement Agencies: Doe v. FBI

handle is hein.journals/gwlr60 and id is 1517 raw text is: Privacy Act THE INCREASED INVULNERABILITY OF INCORRECT RECORDS MAINTAINED BY LAW ENFORCEMENT AGENCIES: Doe v. FBI Gregory R. Firehock Introduction American citizens naturally suspect the accumulation of power that accompanies the government's ability to collect, maintain, use, and disseminate personal information about them. In our demo- cratic society, however, citizens can, through their congressional representatives, establish safeguards against intentional or inadver- tent abuse of that power. The federal Privacy Act of 19741 serves precisely that function. This Chapter examines an individual's right to amend erroneous information about herself contained in United States government records. Under the Privacy Act, as construed by the United States Court of Appeals for the District of Columbia Circuit in Doe v. FBI,2 the FBI may exempt certain systems of records from, among other things, the duty to amend or expunge inaccurate, irrelevant, out- dated, or incomplete records.3 In Doe, the FBI based a background check of an applicant for a government job on records concerning 1. 5 U.S.C. § 552a (1988 & Supp. II 1990). 2. 936 F.2d 1346 (D.C. Cir. 1991) (Edwards, J., joined by Ginsburg, D.H.,J., with Sentelle, J., concurring in part and dissenting in part). 3. 5 U.S.C. § 552a(j)(2), (k)(2) (1988). June 1992 Vol. 60 No. 5 1509

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