Data integrity boards: Institutional innovation and congressional oversight

This article is a preliminary analysis of the first few years of the Computer Matching and Privacy Protection Act of 1988 (CMPPA). The act requires Federal agencies to establish Data Integrity Boards (DIBs) with responsibility to approve written agreements for computer matches in which their agencies are involved. Information for this analysis was collected from the annual reports on computer matching submitted by agencies to the Office of Management and Budget (OMB) for 1990 and 1991 and from 108 matching agreements. The secretaries of several DIBs were also interviewed. The effectiveness of DIBs and matching agreements are analyzed using McCubbins and Schwartz's distinction between “police-patrol” and “fire- alarm” oversight. The article concludes that more active and direct oversight, which would occur through an independent data protection or privacy board, is necessary.