Overview
Title
Agency Information Collection Activities; Proposed eCollection eComments Requested; Revision of a Previously Approved Collection; FBI Records Modification Form (FD-1115)
Agencies
ELI5 AI
The FBI wants to hear what people think about a form they use to keep police records accurate, but they forgot to say how much it might cost, and the instructions might be too hard to understand for some folks.
Summary AI
The Justice Department's Criminal Justice Information Services (CJIS) Division is seeking public comments on a proposed information collection activity. This involves the FBI Records Modification Form (FD-1115), which helps ensure criminal history information is accurately managed in compliance with privacy regulations. The form is necessary for state, local, Tribal, and Federal governments to edit their records accurately since manual updates may be required. Comments will be accepted until March 17, 2025, and focus on the necessity, accuracy, enhancement, and minimization of respondent burden related to the information collection.
Abstract
The CJIS Division, FBI, DOJ, will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
Keywords AI
Sources
AnalysisAI
The document is an official notice from the Criminal Justice Information Services (CJIS) Division of the FBI, under the Department of Justice. It informs the public about a proposed revision to an existing collection of information, specifically regarding the FBI Records Modification Form (FD-1115). This form is essential for managing criminal history records to ensure they are accurate and protect individual privacy rights. The CJIS Division invites public comments on this proposal until March 17, 2025, focusing on several aspects including the necessity and accuracy of the data collection.
General Summary
This notice pertains to a procedural update where the FBI's CJIS Division is seeking feedback on a revision of an information collection tool, the FBI Records Modification Form. This form is crucial for agencies to request changes to criminal history records when digital changes are not feasible. State, local, Tribal, and Federal governments are the primary entities affected, and they are requested to provide comments on various facets of this data collection process. This activity is in compliance with the Paperwork Reduction Act of 1995, emphasizing the importance of public input and the estimated time and effort needed to respond.
Significant Issues or Concerns
There are a few notable concerns regarding the information presented in the document:
Lack of Cost Estimation: While the document does mention the total number of respondents and the time burden, it doesn't provide an estimate for any potential costs. This omission might hide the financial implications for the entities involved.
Complex Language: The language used for public comment instructions could deter individuals unfamiliar with legal or government procedures from participating. Simplifying these instructions might encourage broader public input.
Burden on Smaller Agencies: There is a mandatory obligation for all relevant agencies to respond, which could place a significant burden, particularly on smaller or less-resourced agencies. The document doesn't elaborate on how this might be mitigated.
Submission Method Clarity: For those without electronic access, the document lacks clear guidance on alternative methods for submitting feedback, which may limit participation.
Confusing Terminology: The reference to the Bureau of Justice Statistics in evaluating the necessity of the collection might mislead readers, as this agency is not prominently associated with the form or mentioned elsewhere in the document.
Impact on the Public Broadly
This document primarily impacts government agencies responsible for maintaining criminal history records. For the general public, the implications are less direct, but the assurance of accurate criminal history records has broader social relevance. Ensuring these records are correct protects individual privacy and upholds legal standards.
Impact on Specific Stakeholders
State, Local, and Tribal Governments: These entities are directly affected and required to use the FBI Records Modification Form to update criminal history records. While ensuring accuracy is crucial, the response requirement could be burdensome, particularly for smaller agencies with limited resources.
Federal Government: The federal entities share the responsibility and benefit from the standardized method for requesting record modifications, which contributes to maintaining integrity across criminal history databases.
In summary, while the document underscores the government's commitment to accuracy and privacy in criminal records, some areas could be improved to ensure participation and reduce the burden on smaller agencies. Simplifying language and clarifying cost implications could enhance public understanding and engagement.
Issues
• The document does not specify any costs associated with the collection despite providing an estimate of the total number of respondents and the time burden. This lack of cost estimation might conceal potential financial implications.
• The language used in the instruction for comment submission might be too formal, which can deter participation from individuals not familiar with governmental procedures or legal terms.
• The obligation for state, local and Tribal governments to respond might impose a significant burden on smaller agencies without elaborating on measures to mitigate it.
• The document does not provide clear instructions on alternative submission methods for individuals or agencies that might not have electronic access.
• The phrase 'evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Bureau of Justice Statistics...' could be confusing as the Bureau of Justice Statistics is not mentioned as a relevant party in the metadata or remaining document text.