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National Security Letters — Part 1
Page 384
384 / 1188
At some point several years before my tenure at the FBI began, our process for tracking
NSLs for Congressional reporting purposes shifted from a totally manual process, where NSL data
was written on index cards, to a standalone Access database. This database is referred to in the OIG
report as the OGC database. While the OGC database was a giant technological step forward from
3 x 5 index cards, it is not an acceptable system given the significant increase in use of NSLs since
9/11. First and foremost, the OGC database is not electronically connected to ACS, the system from
which we derive the data. Instead, there is a manual interface between ACS and the OGC database.
An OGC employee is responsible for taking every NSL lead that is sent to OGC and manually
entering the pertinent information into the OGC database. Nearly a dozen fields must be manually
entered, including the file number of the case in which the NSL was issued (typically 15 digits and
alphanumeric identifiers).
Approximately a year ago we recognized that our technology was inadequate and began
developing an automated system to improve our ability to collect this data. The system, in addition
to improving data collection, will automatically prevent many of the errors in NSLs that we will
discuss today. We are building an NSL system to function as a workflow tool that will automate
much of the work that is associated with preparing NSLs and the associated paperwork. The NSL
system is designed to require the user to enter certain data before the workflow can proceed and
requires specific reviews and approvals before the request for the NSL can proceed. Through this
process, the FBI can automatically ensure that certain legal and administrative requirements are met
and that required reporting data is accurately collected. For example, by requiring the user to
identify the investigative file from which the NSL is to be issued, the system will be able to verify
the status of that file to ensure that it is still open and current (e.g. request date is within six months
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