MATRIX FOIA Request to the Georgia Bureau of Investigation

Luanne Duncan
Georgia Bureau of Investigation Open Records Request
P.O. Box 370808
Decatur, GA 30037-0808

Re: Open Records Request

Dear Ms. Duncan:

Pursuant to the Georgia Open Records Act, O.C.G.A. §50-18-70, et. seq., the undersigned hereby requests that you permit inspection and copying of the following public records, including, but not limited to letters, correspondence, tape recordings, notes, data, memoranda, reports, email, computer source and object code, technical manuals, technical specifications, or any other materials under O.C.G.A. §50-18-70(a) regarding the Multistate Anti-Terrorism Information Exchange (MATRIX).

This request includes, but is not limited to, records regarding:

The state's role in the creation of the MATRIX system including but not limited to its membership on the Executive Committee of states supervising the system and the role of Mr. Vernon Keenan, head of the Georgia Bureau of Investigation, in this effort;
The specifications for the MATRIX, including, but not limited to documents regarding storage capacities, throughput (e.g. number of identity files processed per hour), types of computers used, and user manuals;
What personal data is accessed and/or used by the MATRIX, including, but not limited to documents regarding the types of personal data (including, but not limited to drivers' records, financial records, medical information, marriage records, divorce records, Internet usage information, phone records, travel records, voting records, biometric data, educational records, information regarding race, ethnicity, immigration records, criminal justice records and/or gun owners' records) accessed or used by the MATRIX, the contents of any personal information databases related to the MATRIX, the number of individuals whose personal data has been obtained, how that data was obtained, including, but not limited to documents regarding how such data was selected for use in the MATRIX and any agreements and/or contracts to obtain such personal data, including, but not limited to any agreements and/or contracts with Seisint Inc. (Seisint).
Estimates of the cost to the state of utilizing the MATRIX, including, but not limited to projected future costs;
Any procedures for analyzing the data, including, but not limited to the criteria used by the MATRIX to determine whether someone is a terrorist, including, but not limited to the use of information regarding race, ethnicity, religious background, internet usage, travel patterns, political views, political activities and/or consumer purchasing habits in any way, shape or form;
The results of any tests, including, but not limited to any logs or other written descriptions of how any such systems is and/or has been used, the accuracy rates of any such systems while in operation and assessments of the individuals whose data was collected and used;
Who has access to the MATRIX, including, but not limited a complete list of all recipients of data from the MATRIX; any procedures for individuals to find out what information the MATRIX has about them, any procedures for individuals to correct information that the MATRIX has about them, and any procedures for individuals to find out what the MATRIX has determined about them;
Any procedures in place to protect the privacy of the individuals whose data was accessed and/or used by the MATRIX, including, but not limited to documents regarding oversight boards, login restrictions, pop-up screens at sign-on, data security measures, encryption, reduced use of certain criteria (e.g. race and/or ethnicity) and/or data checking to ensure accuracy of the information, how any of the personal data accessed and/or used by the MATRIX will be destroyed, and documentation of any policies permitting such destruction;
Details regarding usage of the MATRIX, including, but not limited to the number of times has the MATRIX been used, the cases or circumstances in which the MATRIX has been used (including, but not limited to instances where the MATRIX was used for non-terrorism investigative purposes and/or for non-criminal investigative purposes), the information that was collected in each instance, the results in instances when the MATRIX was used, including, but not limited to whether any terrorists were caught through use of the MATRIX in each instance, how many innocent people were caught through use of the MATRIX in each instance, notes or logs created during any of these instances where the MATRIX was used, and what happened to people identified by the MATRIX as a threat, the number of times the MATRIX has malfunctioned, the cases or circumstances in which the MATRIX malfunctioned, and what happened in each instance that the MATRIX malfunctioned, any procedures that are in place for use/testing of the MATRIX, including, but not limited to who decides whether the MATRIX will be used/tested in a given case, procedures for handling requests to use the MATRIX in a given case (including, but not limited to requests from state agencies, Federal agencies and/or private entities), the number of requests to use the MATRIX that have been received so far, the entities and/or individuals who have made requests to use the MATRIX, and the number of such requests that have been rejected,
Any legal analyses regarding the MATRIX, including, but not limited to documents regarding whether the MATRIX violates international, federal, state and/or local privacy laws, including constitutional protections;
Organizational details and documents regarding the development and use of the MATRIX, including, but not limited to documents regarding sources of technical and/or financial support for the MATRIX, which federal, state and/or local government agencies are involved and/or cooperating in the MATRIX project, memoranda of understanding between federal, state and/or local government agencies and private companies or other agencies, the extent to which such agencies are involved and/or cooperating in the MATRIX project, what companies (including, but not limited to Seisint), consultants and/or colleges are involved and/or cooperating in the MATRIX project, the extent to which such companies, consultants and/or colleges are involved and/or cooperating in the MATRIX project, what companies, the amount of money spent on developing the MATRIX system so far, the sources for this money, and budgetary outlays for future development and/or maintenance of the MATRIX;,
Records regarding training of people to use the MATRIX, including, but not limited to textbooks, video presentations, contracts and/or agreements to be signed by MATRIX trainees, and the number of people who have been trained to use the MATRIX so far; and
Any records regarding the state's decision to withdraw, or limit its participation in the MATRIX.

Please be advised that this Open Records Request is intended to be as broad and inclusive as permitted by law and is intended to apply to all officers, officials, employees, departments, divisions, bureaus, commissions, councils, and any other private agency, person, partnership, corporation or business entity who has prepared, maintained or received public records.

As required by the Open Records Act, we ask that you respond to this request within three business days. If this request is denied in whole or in part, we ask that you justify your denials by reference to the specific exemptions of the Act, stating the reason why such exemptions apply. You must also release all non-exempt portions of records for which you claim an exemption by redaction. Please waive all costs associated with this request or inform us of the costs and basis for all costs employing the most economical means of production.

If you have any questions, please do not hesitate to contact us. Your immediate attention to these matters is greatly appreciated. Thank you for your assistance.

Sincerely,

Margaret Garrett
Staff Attorney