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2.11 FAA Inspectors’ Access to PRD Records.
2.11.1 Employer. An air carrier or air operator cannot deny an FAA inspector access to PRD-related records for audit or surveillance.
2.11.2 Authority. Title 49 U.S.C. § 41709 provides authority for the FAA inspector assigned to that company to see those records. As a result, the inspector must always have unrestricted access to a company’s PRD-related records at any time during the course of that inspector’s normal surveillance or inspection duties.
2.11.3 Record Denial. Section 119.59(e) states that the failure by any certificate holder to make available to the Administrator upon request, the certificate, OpSpecs, or any required record, document, or report is grounds for suspension of all or any part of the certificate holder’s certificate and OpSpecs, to include PRD records.
2.11.4 Privacy. Each FAA inspector, however, having viewed such records, is also subject to the privacy protection requirements as outlined in 49 U.S.C. § 44703(i)(9). The FAA inspector must make every effort to protect the privacy of the pilot and the confidentiality of the PRD-related records of that pilot.
3-1 CHAPTER 3. PILOT RECORDS IMPROVEMENT ACT OF 1996 Note: The information provided in Chapter 3 is specific to PRIA and may not be the same as described in Chapter 2 for the PRD.
3.1 Purpose of This Chapter. This chapter provides information to facilitate compliance with the provisions of Title 49 of the United States Code (49 U.S.C.) § 44703(h), the Pilot Records Improvement Act of 1996 (PRIA). PRIA requires air carriers and other operators to gather and share information relating to a pilot-applicant’s qualification and safety background. An air carrier or air operator must request those records so it can make an informed decision before an individual is placed into service as a pilot. PRIA applies to any hiring air carrier or air operator, whether they hire pilots directly or by contract. Part 111 specifies that PRIA remains in effect for 3 years and 90 days after part 111 is published.
3.2 How to Use This Chapter. The FAA wrote this chapter for three audiences: the pilot-applicant, hiring employers that request PRIA records, and former employers that respond to PRIA records requests. You do not have to read the entire document to find the information you need. Paragraph 3.4 describes the applicability of PRIA. Pilots applying for a job with an air carrier or air operator that will have to request PRIA records should read paragraph 3.9. Hiring employers should read paragraphs 3.10 and
3.12; and those employers responding to PRIA records requests should read paragraph 3.11. Chapter 4 is for all affected parties, as it contains some PRIA specific definitions, resources, and PRIA contact information. See paragraph 2.10 for information about how the PRD can be used to comply with PRIA during the transition in which both PRIA and PRD are in effect.
3.3 PRIA Background. On October 9, 1996, the President approved the Federal Aviation Reauthorization Act of 1996 (the Act). The Act amended 49 U.S.C. to reauthorize programs of the FAA and to effect certain changes, including pilot records. The law is commonly referred to as PRIA and is contained in Section 502 of Public Law (PL) 104-264, Federal Aviation Reauthorization Act of 1996. PRIA was enacted primarily as a result of certain accidents attributable to pilot error. In some of those cases, the subsequent employer found that the pilots had previous histories of poor performance, but the background of these pilots had not been checked. PRIA was amended to make clarifications and relieve air carriers of unnecessary burdens. These amendments to PRIA are in 49 U.S.C. § 44703(h), (i), and (j).
3.3.1 PRIA Review. A pilot may begin training with the new employer before the PRIA check has been completed. However, all PRIA checks must be completed, evaluated, and approved before the individual can begin service as a pilot for that hiring employer, in accordance with 49 U.S.C. § 44703(h)(1).
3.3.2 Pilot Records Database (PRD). The Airline Safety and Federal Aviation Administration Extension Act of 2010 (the Act) amended PRIA and required the FAA to create the PRD.
The PRD is required to contain pilot records dating from August 1, 2005 for FAA certification events, enforcement records, pilot employment history, training data, and
3-2 drug and alcohol testing records. Once the transition period is complete, the PRD will replace PRIA. Until full implementation of the PRD, PRIA remains in effect. Therefore, air carriers and other operators who employ pilots must continue to provide pilot records to an air carrier or air operator seeking information on an individual pilot in accordance with PRIA. PRIA requires air carriers to evaluate all available pilot records prior to making a hiring decision. See paragraph 2.10 for information about how the PRD can be used to comply with portions of PRIA.
3.4 Applicability.
3.4.1 Affected Parties. PRIA specifically applies to the following:
3.4.1.1 Any U.S. air carrier operating under 14 CFR part 121 or 135, or any U.S. air operator under 14 CFR part 125 or 135 for the purpose of requesting records.
3.4.1.2 Any U.S. air carrier operating under part 121 or 135, any U.S. air operator operating under part 125 or 135, other person, or trustee in bankruptcy for an operator that employed the individual as the pilot of a civil or public aircraft at any time during the 5-year period before the date of the individual’s employment application for the purpose of furnishing records.
3.4.1.3 Any individual who is applying for a position as a pilot with a U.S. air carrier or operator, and has been employed as a pilot of a civil or public aircraft at any time during the 5-year period before the date of the individual’s employment application for the purpose of employment.
3.4.1.4 Single pilot operators are subject to the provisions of PRIA. Complete the PRIA forms as both the air carrier representative and the pilot (as subject of the request). In the margin of the request, enter the statement “SINGLE PILOT OPERATOR” in large letters to identify yourself as such.
3.4.1.5 Operators not required to request records when hiring pilots should still respond to requests for PRIA-related records by forwarding such records that the operator may have accumulated concerning the pilot-applicant within the previous 5-year period or a statement to the effect that there are no records available to be forwarded.
3.4.2 Determining Whether PRIA Applies to You When Hiring a Pilot. Use the following checklist to determine whether PRIA requires you to request records for a pilot. You must request records concerning a pilot-applicant if you answer “yes” to either of the two questions below.
3.4.2.1 Are you an air carrier or operator conducting operations in accordance with 14 CFR part 91 subpart K (part 91K), 121, 125, or 135?
3.4.2.2 Do you engage in air transportation, as defined in 49 U.S.C. § 40102(a)(5)?
You engage in air transportation if you provide:
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• Foreign air transportation (flag operation),
• Air transportation on an interstate basis, or
• Transportation of U.S. mail.
Note: Notwithstanding the above comments, all operators should consider voluntarily requesting PRIA records and any other records that may be available.
3.4.3 Contract or Shared Pilots Concerning PRIA. Before allowing an individual to begin service as a pilot, PRIA requires an air carrier or air operator to request and receive PRIA-related records, regardless of whether they hire the pilot directly or by contract. In all cases, the PRIA burden is on the air carrier or air operator, not the company providing the pilot under a contract, or the individual pilot. Therefore, if an air carrier or air operator is going to utilize the temporary services of a contract or shared pilot provided by a staffing type agency or other concern, the burden remains with the utilizing air carrier or air operator to comply with the PRIA statutes.
3.4.4 PRIA Participation by Part 91 Operators. If you operate under part 91 and you receive a request for a pilot’s records under the authority of PRIA, you should respond. Therefore, you should furnish any PRIA-related records you accumulated on an individual you employed as a pilot within the previous 5 years, or if there are no records to forward, simply state that there are none and return the request. This will enable the requestor to close out and complete their PRIA checks and then proceed with their hiring process.
3.4.4.1 If you operate as a fractional ownership under part 91K you are required to request and evaluate records in accordance with § 91.1051. If you are an operator as defined under § 91.147, you must request drug and alcohol testing records when hiring a pilot-applicant for your air tour operation in accordance with 49 CFR part 40.
3.4.4.2 If you are a pilot who has been continuously employed by the same air carrier or air operator with no break in service since the initiation of PRIA on February 6, 1997, your employer is not required to have a PRIA Background Report on file.
3.5 Company Records vs. PRIA Records. Pilot employers typically maintain records that exceed the scope of records to which PRIA applies. Such records are referred to as “company records,” whereas the records maintained and provided by operators in accordance with PRIA are referred to as “PRIA records.” The difference between the record types can easily create confusion among those involved during review.
3.5.1 Company records are events or actions memorialized by an air carrier or operator to document compliance with a statute or regulation or those maintained through a company’s own initiative. These records typically consist of documented training and qualification events, performance, and employment-related activities during the period
3-4 that an individual is employed by a company as a pilot. Many company records exceed the scope of PRIA.
3.5.2 PRIA records are a collection of company records memorialized by a current or former employer during the previous 5 years from the date of the request that meet the policy outlined in this AC and the requirements of 49 U.S.C. § 44703(h). These records are used to assist an air carrier or operator in making a hiring determination. PRIA records are not forwarded from a receiving air carrier to another requesting air carrier through a future PRIA records request.
3.5.3 When a pilot is seeking employment with an employer that is required to review records in accordance with PRIA, the employer will request records from the pilot’s current and/or previous employers. The previous employers will then assemble copies of the appropriate records for the past 5 years.
3.5.4 Once the company records have been assembled by the current and/or former employers of the pilot applicant, at that point, that subset of company records become PRIA records.
3.5.5 Those PRIA records will be archived and maintained completely separate from the hiring air carrier or operator’s company records. PRIA records received through a PRIA records request should never be actively used again, other than for inspection and review by that company’s Principal Operations Inspector (POI).
3.5.6 PRIA records received as a result of a PRIA records request should never be included in an employer’s own company records when that employer receives a subsequent PRIA records request. The company holding the PRIA records must respond to a PRIA records request only from their company records and never forward another company’s PRIA records as part of the records sharing process.
3.6 The Request Process. The following is a brief overview of the entire PRIA process.
Subsequent paragraphs detail the roles and responsibilities for the pilot-applicant, the hiring employer, and the current or former employer. See paragraph 2.10 for information about how the PRD can be used to comply with portions of PRIA.
3.6.1 Initiation. The hiring employer initiates the process.
3.6.2 PRIA Records Request. Both the pilot-applicant and the hiring employer complete the PRIA records request forms.
3.6.3 Employer. The hiring employer sends the request forms to the:
• FAA,
• National Driver Register (NDR), and
• Current and previous employers.
3.6.4 Response. Respondents answer the PRIA records requests.
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3.6.5 Review. All pilots/applicants may review records submitted about them to the FAA, NDR, and current and previous employers.
3.6.6 Evaluation. The hiring employer reviews and evaluates the results.
3.6.7 Records Maintenance. The hiring employer maintains all PRIA-related records.
3.7 Designated Agent (DA). A requesting air carrier or air operator has the option of employing a “third-party processor,” commonly known as a DA or proxy, to complete all of their PRIA checks.
3.8 Best Practices. The FAA expects that pilots, hiring air carriers, and air operators, as well as past employers, will use these best practices to ensure they are operating to the highest level of safety.
3.8.1 PRIA Records Request. The FAA expects all hiring air carriers and air operators to request all FAA records of proficiency and competency as well as airmen certification practical test results. These records can be requested by obtaining a release from the applicant (see Appendix G).
3.8.2 Release Form. Hiring air carriers and air operators should not consider an applicant for employment if that applicant will not sign the release for the additional FAA records.
3.8.3 Disclosure. The FAA expects a pilot/applicant to disclose all pilot testing failures to any potential employer to which PRIA applies.
3.9 Information for the Pilot-Applicant.
3.9.1 Pilot-Applicant’s Tasks During PRIA Records Request Process. If you are an individual who is applying for a job as a pilot, your hiring employer will initiate the PRIA records request process. Per 49 U.S.C. § 44703(h)(5) and (6), the hiring employer must first notify you in writing that it will request records about you and obtain your written consent by signature.
3.9.1.1 Complete PRIA Records Request Forms.
3.9.1.1.1 The hiring employer or a DA will provide several forms to request PRIA-related records from the previous 5 years only. You will complete and sign these forms to grant your consent for the FAA, your previous employer(s), and the NDR to release your records.
3.9.1.1.2 The Aviation Data Systems Branch will provide information concerning your current airman medical certificate. It will also give information on your current airman certificates indicating level, category, class, and associated type ratings, including any limitations to those certificates and ratings. From the previous 5-year period, the FAA will also summarize any closed legal enforcement actions against you that resulted in findings of violations that were not subsequently overturned. However, the FAA will report any formal
3-6 closed certificate actions on file, such as suspensions, civil penalties, or revocations indefinitely.
3.9.1.1.3 The hiring employer will ask your previous employer(s) to provide records pertaining to you, except for those related to flight time, duty time, or rest time. A previous employer will provide records on your performance as a pilot concerning your training, qualifications, proficiency, and professional competence, including any comments or evaluations by check airmen; any disciplinary actions that the previous employer did not overturn; and any release from employment or resignation, termination, or disqualification from employment. Additionally, under PRIA, your former Department of Transportation (DOT)-regulated employer(s) will provide records of drug and alcohol tests performed under 49 CFR part 40, even if the employers were not aviation entities.
3.9.1.1.4 If this is your first job as a pilot, but you were previously subject to DOT-regulated drug and alcohol testing, your hiring employer must request your drug and alcohol test results from your previous employer(s) in accordance with 49 CFR part 40.
3.9.1.1.5 The NDR will furnish your applicable motor vehicle driving records.
3.9.1.2 Request Copies of Records.
3.9.1.2.1 Records from the FAA. The Aviation Data Systems Branch will automatically send you an identical copy of the PRIA verification letter that it furnishes to the hiring employer. As a security measure, the Aviation Data Systems Branch will send this report to your home address, as shown in the records maintained by the Airmen Certification Branch. Ensure that the Airmen Certification Branch has your current home address by updating it online at https://registry.faa.gov or by calling toll free at 866-878-2498. In addition, the hiring employer may, at its discretion, request a record of your Notices of Disapproval from the FAA.
3.9.1.2.2 Records from Previous Employers and the NDR. If desired, you can request copies of records that your previous employer(s) maintained, including those from the NDR. If the hiring employer uses the recommended FAA forms to request records, then FAA Form 8060-11A, Airman Notice and Right to Receive Copy – Air Carrier and Other Records (PRIA), is the proper form to use when requesting copies of your pilot and drug and alcohol testing records from your previous employer(s). If you requested a copy of your current NDR records, the hiring employer should furnish them to you after receiving them from the NDR.
Note: PRIA permits respondents to charge a reasonable fee in a “statement of payment” to recoup the cost of furnishing records to you.
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3.9.1.3 Review Records and Submit Corrections. You may review the records received and, if necessary, submit a written statement to correct any inaccuracy or omission in your records. The hiring employer should include your statement in the PRIA-related records file that it compiles on you to represent your viewpoint concerning those records or entries. It is recommended that you ensure that the hiring employer has a copy of any such corrections.
3.9.1.4 Sign Release of Liability. Hiring employers or former employers may require you to sign a release from liability for records other than the drug and alcohol testing records, in accordance with 49 U.S.C. § 44703(h)(2)(B). The release from liability can state that you will not make any claim against them for requesting or furnishing PRIA records, but would not apply if an employer furnishes information known to be false or maintained it in violation of a criminal statute. Under 49 CFR part 40, § 40.27, an employer must not ask an employee to sign a consent, release, waiver of liability, or indemnification agreement with respect to any part of the drug or alcohol testing process.
3.9.1.5 Your Right to Receive Copies of Records. In accordance with 49 U.S.C.
§ 44703(h)(6), the FAA and your former employer(s) are required to give you written notice of the request and notice of your right to receive copies of the records within 20 calendar-days of receiving a PRIA records request.
3.9.1.6 PRIA Records Request. If you have requested a copy of your records, these respondents (FAA or former employer) can fulfill this requirement by providing the records to you within 30 calendar-days in accordance with 49 U.S.C. § 44703(h)(10).
3.9.2 A Pilot’s Expectations and Protections under PRIA. All professional pilots whom a hiring employer is considering for employment have certain protections concerning the request, transfer, receipt, evaluation, and maintenance of their records.
3.9.2.1 PRIA Statutory Provisions. In accordance with PRIA, the hiring employer must provide you with the following:
1. Written notification that the hiring employer will make a request for your PRIA-related records.
2. A consent form to sign for the release of those records.
3. An opportunity to request a copy of those records if so desired.
Note: Use of FAA forms provided to employers fulfills the three requirements stated above.
4. An opportunity to submit a written comment or memorandum to a former or potential employer when you believe there are inaccuracies in your PRIA-related records. This written comment should be submitted to the previous employer for entry into your records maintained by the previous
3-8 employer; however, it is recommended that you also ensure that the hiring employer has received a copy of the document as well. If not, be prepared to provide them with one when you review those records.
5. An opportunity to review and comment on your PRIA-related records. The air carrier or air operator should also make available a copy of the requested records within a reasonable period of time, but not later than 30 calendar-days after the date of your written request. This is especially true when distance prohibits you from reviewing your records in person.
Note: We recommend that you review your PRIA-related records, if possible, before applying for a new job. This can help you ensure that your records are in order and that you address all problem areas in advance.
3.9.2.2 Your Privacy Protections Under PRIA. The confidentiality of your PRIA records will be protected in the following manner:
1. PRIA limits a hiring employer receiving your PRIA records to using them only to assess your qualifications in deciding whether to permit you to begin service as a pilot.
2. Accordingly, only company personnel directly involved in the hiring process may view and evaluate the records.
3. The air carrier or air operator should maintain PRIA-related records for the duration of your employment with them and also for a suggested period of 5 years after the termination of that employment. Anyone possessing PRIA-related records must ensure that individuals not involved in the hiring process do not view or have access to your records, in accordance with 49 U.S.C. § 44703(h)(11). The one exception is the FAA inspector, who cannot be denied access to a PRIA-related system of records when conducting surveillance or inspection of those records.
However, when viewing such records, the FAA inspector must also make every effort to protect your privacy and the confidentiality of your PRIA- related records.
3.9.2.3 Records Concerning Disciplinary Actions. See paragraph 3.11.5.2 for a discussion of records to be furnished concerning disciplinary actions regarding an individual’s performance and competence as a pilot.
3.9.3 Pilots Formerly Employed by Government Agencies. If a government agency (Federal, state, or local) employed you as a pilot, the hiring employer must contact the agency for your records in accordance with 49 U.S.C. § 44703(h). You should provide a brief statement and a signature consenting to the release of background information concerning your flight training, experience and qualifications, proficiency, other related safety history, drug and alcohol testing records, and any subsequent actions taken as a result of those tests. Send this request to the governmental agency where you worked as a pilot.
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3.9.4 Reporting of Previous Employers. All pilots/applicants should ensure that all previous employers where the applicant was employed as a pilot within the past 5-year period are reported to the hiring air carrier or air operator on FAA Form 8060-11, Air Carrier and Other Records Request (PRIA). Only in this way can the air carrier or operator fulfill the full purpose and mission of PRIA and the pilot avoid the possibility of falsifying an FAA form.
3.9.5 Additional PRIA Resources for Pilots. For additional resources and information, visit the PRIA website at https://www.faa.gov/pilots/lic_cert/pria. Direct any questions to the Regulatory Support Division at 405-954-4431.
3.10 Information for the Hiring Employer on PRIA Procedural Considerations.
3.10.1 Initiate the PRIA Records Request Process. If you are an air carrier or air operator hiring a pilot, you (or your DA) will initiate the PRIA records request. Using the forms available from the FAA will help you comply with the statutory requirements of PRIA.
You can obtain the forms and information about filling out these forms from the PRIA website at https://www.faa.gov/pilots/lic_cert/pria/forms_docs and from the FAA website at https://www.faa.gov/forms. See Appendix G for guidance concerning the overview and use of these forms. We recommend that you use these current FAA forms instead of old versions or self-designed forms because those forms might not produce the results required by statute. The forms are:
• FAA Form 8060-10, FAA Records Request (PRIA).
• FAA Form 8060-10A, Airman Notice and Right to Receive Copy – FAA Records (PRIA).
• FAA Form 8060-11, Air Carrier and Other Records Request (PRIA).
• FAA Form 8060-11A, Airman Notice and Right to Receive Copy – Air Carrier and Other Records (PRIA).
• FAA Form 8060-12, Authorization for Release of DOT Drug and Alcohol Testing Records Under PRIA and Maintained Under Title 49 Code of Federal Regulations (49 CFR) Part 40.
• FAA Form 8060-13, National Driver Register Records Request (PRIA).
3.10.2 Using a DA to Respond to PRIA Records Requests. You may contract with a DA or proxy to process PRIA records requests and furnish records to hiring employers and pilots/applicants. Although you may delegate this work to a DA, you are ultimately responsible for fulfilling the requirements. Also note that, since a DA cannot retain PRIA records in a records system of its own, you are responsible for maintaining PRIA records.
The release of the documents must specify exactly who is to receive the documents, and a blanket release to provide the documents to a category of parties is prohibited under 49 CFR §§ 40.321(b) and 40.351(d) of the drug and alcohol testing regulations. A guidance document titled “PRIA Instructions for the Designated Agent (DA)” is available on the PRIA website at https://www.faa.gov/pilots/lic_cert/pria/requesting.
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3.10.3 The Hiring Employer’s Role During the PRIA Records Request Process.
3.10.3.1 Obtain Consent and Notify Pilots/Applicants of Their Right to Receive Copies. PRIA requires you to notify all pilots-applicants in writing that you will be requesting their records, obtaining their written consent to release the records, and informing them of their right to receive copies. You can fulfill these requirements by using the FAA forms.
3.10.3.2 Complete PRIA Records Request Forms. Fill out the applicable sections of each form, then have the pilot-applicant complete the forms.
Note: Provided no other provisions of law or agreement to the contrary exist, you can require the pilot-applicant to execute a release from liability against any claim he or she may make from your use of PRIA records in accordance with 49 U.S.C. § 44703(h)(2). Release from liability can state that the applicant will not make any claim against entities who request or respond to PRIA records requests.
3.10.3.3 Send Forms to the Appropriate Recipients. Mail, fax, or email your scanned applications to the recipients and retain documentation of when the recipient received them (e.g., fax confirmation page). If mailing, we recommend that you send forms through the United States Postal Service (USPS) (certified, return receipt requested) or a private mail carrier that documents the date of delivery.
3.10.3.4 Forward FAA Form 8060-10 to the Aviation Data Systems Branch. You can fax your completed PRIA records request(s) for FAA records to the Aviation Data Systems Branch at 405-954-4655, ATTN: PRIA; or email them to 9-amc-afs620-pria@faa.gov. You can also mail your completed PRIA records request(s) for FAA records to:
1. Via Regular Mail.
Federal Aviation Administration ATTN: Aviation Data Systems Branch (PRIA) P.O. Box 25082 Oklahoma City, OK 73125-0082
2. Via Expedited Mail.
Federal Aviation Administration ATTN: Aviation Data Systems Branch (PRIA) 6500 South MacArthur Blvd.
ARB Building, Room 313 Oklahoma City, OK 73169
3.10.3.5 Retain Original FAA Form 8060-10A. Retain the original FAA Form 8060-10A in your PRIA-related records file after giving the pilot-applicant a signed and completed copy of the form.
3-11 Note: Do not forward FAA Form 8060-10A to the FAA. The Aviation Data Systems Branch will automatically mail to the pilot-applicant a courtesy copy of the PRIA Verification Letter that it furnishes to you.
3.10.3.6 Send Forms to Individual’s Previous Employers. Send FAA Forms 8060-11, 8060-11A, and 8060-12 to all previous employers who employed the individual as a pilot within the previous 5-year period. If the individual was not employed as a pilot before, you must request the drug and alcohol testing records from those previous employers and you must ask the questions required by 49 CFR. Refer to 49 CFR § 40.25(j). Examples of previous employment that would trigger this requirement are work in another FAA-regulated safety sensitive function, such as flight attendant or aircraft maintenance or preventive maintenance duties, or work in another DOT-regulated industry where he or she was subjected to drug and alcohol testing under 49 CFR part 40 (e.g., as a truck or bus driver, or pilot for a pipeline operator flying under part 91 operations).
3.10.3.7 Send Complete NDR Application to State DMV. Send a completed NDR application form to the state chief driver’s licensing official or Department of Motor Vehicles (DMV) that issued the driver’s license to request the appropriate NDR-related records. Many state DMVs will require the original form, so you might have to mail the request instead of faxing it. We recommend that you call the state DMV to confirm whether it needs the original form and if any fees apply.
Note: Send your NDR request to the resident state of your pilot applicant. As you are preparing your NDR request we suggest that you use that state’s own application form rather than FAA Form 8060-13, since most states are not familiar with FAA Form 8060-13 and may not process it. You should be able to make an online query to find that state’s particular application form for a third party and also what the cost will be per request.
3.10.3.8 Part 91 Requests. If you are a part 121 or 135 air carrier or a part 125 air operator that is preparing to hire a pilot whose previous experience is only with part 91 operators, you should still send a PRIA records request to these companies for any training or safety-related information that those companies may have and the company should respond to that request. If the company has no information, the company should indicate to you that no information is available.
3.10.3.9 Privately Employed 14 CFR Part 61 Flight Instructors. If the pilot you are preparing to hire only worked privately as an individual part 61 flight instructor, there is no need to prepare and send a PRIA records request because there is no company from which to request records.