The Privacy Coalition

The Privacy Coalition is a nonpartisan coalition of consumer, civil liberties, educational, family, library, labor, and technology organizations that have agreed to the Privacy Pledge. The organization formed in February 2001. View a list of member organizations.

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DOD Recruitment Database

Draft Resolution on DOD Database

Whereas, the Department of Defense (DOD) in criminal violation of the Privacy Act has created the largest single centralized facility to compile, process, and distribute information on 30 million 16-25 year-olds in the United States.

Whereas, the Privacy Act Law is intended to safeguard the privacy of citizens requiring government agencies to show an individual any records kept on him or her. The Privacy Act requires agencies to follow certain principles, called "fair information practices," when gathering and handling personal data. The Privacy Act places restrictions on how agencies can share an individual's data with other people and agencies. Finally, the Privacy Act lets individuals sue the government for violating its provisions.

Whereas, the DOD was required by the Privacy Act to provide notice 30-days before beginning their work on the Joint Advertising and Marketing Research Studies recruiting database in 2002. The federal agency delayed making public notice of this project until a Federal Register notice published on May 23, 2005.

Whereas, the DOD has contracted with Benow a private direct marketing firm, which has been acquired by Equifax, to mange the database. This database will include personal information, such as full name, full address, e-mail address, telephone number, date of birth, gender, grade point average, ethnicity, school name, college intentions, field of study, and social security number.

Whereas, the sources of information for the DOD database include the High School Master File and the College Students Files, which are compiled for purposes that are unrelated to an interest in military service or recruitment. The High School Master File is created from information provided by state motor vehicle departments; and the commercial brokers American Student List and Student Marketing Group.

Whereas, the American Student List sells databases of children's names in grades K-12 overlaid with data on sex, age, whether they own a telephone, income, religion, and their race or ethnicity. This information is often obtained from surveys that are administered while children are at school under the pretense of college admissions and other education-related purposes.

Whereas, in August 2002, the New York Attorney General filed suit against Student Marketing Group for deceptive practices that deceived students into providing personal information to them.

Whereas, in October 2002, the Federal Trade Commission (FTC) settled a case against American Student List for collecting personal information from children using deceptive practices.

Whereas, the DOD's Joint Advertising Marketing Research Studies recruiting database purchases lists from commercial data brokers: American Student List and Student Marketing Group.

Whereas, the DOD is abusively using the social security number s (SSN) of those included in the Joint Advertising Marketing Research Studies recruitment database. The Privacy Act explicitly limits the collection and use of the Social Security Numbers by federal agencies. The DOD cannot rely on Executive Order 9397, signed by President Roosevelt in 1943, which allows the use of SSNs when federal agencies are establishing "accounts." The DOD is not administering an account system for the benefit of individuals, but an enumeration system for the benefit of the agency.

Whereas, there is no evidence that Equifax has been instructed by the DOD to comply with all relevant provisions of the Privacy Act.

Therefore be it resolved, that we are aware that the DOD faces difficult challenges to recruiting for military service, however, we consider for the aforementioned reasons that their current effort is in violation of the Privacy Act and we seek the withdrawal of our institution's participation in establishing the DOD's Joint Advertising and Marketing Research recruitment database.

(Institution Name)



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Organizations Concerned about the Database and Military Recruiting