Alterations (also known as “Significant Alterations”)

An alteration to an existing system of records occurs as a result of a change in the manner in which records are organized, indexed or retrieved, or a change in the nature or scope of the records.

A System of Records Notice (SORN) is considered “altered” if a change occurs in one or more of the following:

  • A significant increase in the number, type, or category of individuals about whom records are maintained. Example: A system covering physicians that has been expanded to include other types of health care providers, e.g., nurses, technicians, etc.

    NOTE: Increases attributable to normal growth should not be reported. Increases in numbers of individuals due to normal growth are not considered alterations unless they truly alter the character and purpose of the system.
  • A change that expands the types or categories of information maintained. Example: A benefit system which originally included only earned income information that has been expanded to include unearned income information.
  • A change that alters the purpose for which the information is used. Example: The system is now also used for statistical purposes.
  • A change to equipment configuration (either hardware or software) that creates substantially greater access to the records in the system of records. Example: Locating interactive terminals at regional offices for accessing a system formerly accessible only at the headquarters would require a report.
  • The addition of an exemption.
  • The addition of a routine use pursuant to 5 U.S.C. 552a(b)(3).

If an alteration needs to be made to a system of records, Army Activities must amend the existing SORN and republish it in the Federal Register. The proposed alterations to the existing system of records should be provided in the Narrative Statement, Proposed Changes, the complete Altered SORN, and the Supplementary Information (as applicable).

Appendix I to OMB Circular No. A-130, Federal Agency Responsibilities for Maintaining Records About Individuals serves as the baseline for distinguishing between the criteria for drafting a new SORN versus amending an existing SORN.

Altering an Existing SORN