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Implement records management/data management policies with metadata tagging for individual fields in a record.

This could cover Unclassified/Secret/etc. as well as PII/PHI. Then when a FOIA requests comes in, the software handling the release automatically redacts the PII/PHI fields, does a timestamp check for the Secret+ fields and redacts if < (xx years).

This is why best practice is to put classification markings on every paragraph in a classified document (seems like a pain but clearly it's important and needed). It builds a mental "muscle memory" in the staff for granular metadata tagging that eases the production of derivative classified products, Foreign Disclosure, and FOIA.




Or in this case, make companies submitting to the FDA file a sanitized version of the report along with the full one.


This would go a long way towards making the process feasible.




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