Privacy Act Data Question

[Tad Blanchard <Tad.M.Blanchard.1@gsfc.nasa.gov>]

Greetings RADSAFERS,

We have a system whereby personnel who will be using radioactive materials or radiation producing devices must submit a form which includes their training and experience.  

While reading the Privacy Act I noted that if you have a form that includes the persons Name and Education this would constitute "Privacy Act Data" and must be treated accordingly (similar to our radiation dosimetry files).

My question is this:  Is there a difference between "training" and "education" as it applies to the Privacy Act? 

We are trying to determine if our approval forms require handling under the Privacy Act.  Our forms are similar to those used at most research facilities.  A similar form used by the University of Pennsylvania (Application for Authorization to Use Radioactive Materials) can be seen at 

http://www.rso.upenn.edu/frame/f_form/default.html

This may be an interesting topic for the entire RADSAFE group but if you don't believe so, email me directly with your opinion.  Thanks.



************************** /^\   /^\ ***********************************
Tad Blanchard             /___\ /___\   NASA-Goddard Space Flight Center
Ass't Rad Safety Officer       O         Code 205.9, Greenbelt, MD 20771
Parallax, Inc                 / \                    Phone: 301-286-9157
A Member of the OHI Team     /___\                   Fax:   301-286-1618
               mailto:tmblanch@pop200.gsfc.nasa.gov
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