The memorandum is dated September 17, 2001, which is several days after the terrorist attacks of September 11, 2001. It is also several months after the Wall Street Journal published an article titled "FBI's Reliance on the Private Sector Has Raised Some Privacy Concerns", by Glenn Simpson, dated April 13, 2001. The FBI memorandum addresses whether the FBI may pay for access to ChoicePoint's database of personally identifiable information about Americans. Were the FBI to collect and maintain such data itself, it might violate the Privacy Act.


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