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(3) for a routine use as defined in subsection (a)(7) of this section and described under subsection (e)(4)(D)." 5 U.S.C. § 552a(b)(3). Reacting to Bartel, OMB issued steerage indicating that data which have "traditionally" been thought of to be within the public area, and people which might be required to be disclosed to the public – corresponding to names and workplace telephone numbers of company staff – can be launched with out ready for an actual FOIA request. 487, 503 (E.D.N.Y. 1979) (finding subsection (b)(2) inapplicable to the "voluntary re-release" of a previous press release (that had been made prior to the efficient date of the Privateness Act) as "nothing in the FOIA seems to require such data to be released in the absence of a request therefor"). In one case prior to Bartel, it equally had been held that subsection (b)(2) was not obtainable as a protection for the disclosure of data in the absence of a FOIA request. The Court of Appeals for the District of Columbia Circuit significantly restricted the utility of subsection (b)(2) as a defense by holding that subsection (b)(2) cannot be invoked except an agency really has a FOIA request in hand. In gentle of Reporters Comm., private info of the type protected by the Privateness Act is less prone to be "required" to be disclosed under the FOIA, inside the meaning of subsection (b)(2). The Time Is Now For Information Privacy Regulation, However

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