The issue concerns the CD-346 form included in the TIIAP
 guidelines.  The Privacy Act Advisory Statement states that
 the principal purpose of the requested information is "To
 establish the character and integrity of principal officers
 and employees of organizations, firms, or recipients or
 beneficiaries of grants, loans, loan guarantee programs, or
 contracts." [Excuse me?]  The statement says that response
 is voluntary, but the "The Effects on You" part threatens
 that your proposal may not be reviewed if the information is
 not received.

 The reason private institutions have a right to be upset is
 that they are specifically required in the guidelines (I
 saw no mention of it being voluntary) to submit highly
 personal information on PI's and institutional officers,
 whereas public institutions are specifically exempted from
 this indignity.  Either Commerce questions the "character
 and integrity" of officials more at private institutions
 than at public institutions -- or there is some legal snag
 that prevents them from invading everyone's privacy. [sorry,
 could not resist sarcastic editorial comment]

 DoC's citations for the requirement are 15 USC 1519, 4 USC
 3211 (12), 44USC 3101, and 13 CFR 309.2.

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 Bill Schulze, Director
 Research Administration
 University of Nevada, Las Vegas

 xxxxxx@ccmail.nevada.edu
 voc (702)895-1357
 fax (702)895-4242

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