◆ SpookStack

tefervals from the FEI, the NSD will promptly notify the Atterney General if it appears that the incident suggests the need for a change in policy, training or oversight mechanisms. The NSD will also cepart to the CPCLO any IOBs that raise s@rious civil rights or privacy issues. *The NSD will also report to the Attorney General every six months on all IO6 referrals reported by the FBI during the preceding six-month period. This mechanism will help identify trends and pokential future problems. New Measures to Address NSL Tracking *In @arly 2006, the FBI began developing a new NSL tracking database. The Web-based system will be piloted in the PBI‘s Washington Field Office in the summer of 2007 and will be deployed to four large field offices in late 2007. The new system will include a Field that will identify whether the NSL recipient complied with the request and will possibly allow for entry of notes or comments on the response. *Until the new system is deployed, FBI field offices will report monthly on NSLs that have been issued. The FRI Office of General Counsel will ensure that the NSLs comply with applicable statutes, guidelines, and policies. *To obtain a better accounting of past use of NSLs and correct inaccuracies in Past Congressional reports, the PEI Director has ordered an intensive process to query clher computer systems to locate files where NSLs may have been issued but nek reperted to FRI Office of General Counsel for inclusion in its tracking database. In addition, the FRI Office of General Counsel is correcting any data entry e€rrers in the #xisting database. The Attorney General has also mandated that the Justice Department’s NSD and CPCLO advise him on additional steps that should be taken to correct the inaccurate mumbers reported to Congress. *On March 5, 2007, the FBI issued a new policy requiring the retention of copies of signed NSLs. New Training and Guidance on NSLs *The PEI will ré-lissue comprehensive guidelines throughout the Bureau concerning the proper use of NSLs. The FBI Office of seneral Counsel will evaluate existing Guidance and make necessary revisions in consultation with the Department of Justice!s National Security Division. “The FEI has begun developing a new training course on the proper use of NSLs that will be available to FBI personnel through the Internet. After the course development is complete, the FBI will issue a directive mandating training for Bll Special Agente-in-Charge, Assistant Special Agents-in-Charge, aS well as all appropriate PBI agents and analysts. *In the meantimé, the FBI has ordered that anytime an FBI Office of General Counsel attorney is traveling in the field for any reason, the attorney must schedule manclatery NSL training. The FBI will consider whether actditional training an WSLs for new agents is needed. *The Justice Department’s Executive Office of U.S. Attorneys will review its existing training materials and quidance for terrorism investigations and prosecutions to ensure that NSLs are properly described in such materials. Mew Oversight of the Use and Retention of NSL-Derived Information *A working group co-chaired by the Offices of the Director of National Intelligence and the Justice Department’s CPULO has been convened to examine how NSLederived information is used and retained by the FBI. The FBI’s Privacy Offleer as well as a representative from the Justice Department’s NSD will be represented on this working group. The working group will examine hew the NSL records are stored and disseminated and determine the retention practices of other agencies with NSL authorities, Review of Role of FRI’a Divisien Counsel] *The Justice Department’s HSD and the PRI have begun examining whether the FAI’s organitational structure should be changed to have FBI’s Division Counsel in field offices report to the FBI's Office of General Counsel in Headquarters rather than to field office Special-Agents-in-Charge.