TN 8 (05-09)

A. Policy

1. General

a. Authorized Disclosures

Although authorized disclosures of information are usually in writing, it is permissible to disclose information over the telephone if appropriate measures are taken to assure that the requester is entitled to receive it.

CAUTION: Under no circumstances can medical records be released over the telephone even if the caller provides the SSN of record.

b. Prohibition Against Disclosure/Access When Caller Does Not Provide the Social Security Number (SSN) of Record

Increases in the availability of personal information and in identity theft have caused SSA to be especially careful when disclosing information over the telephone when a requester cannot provide the SSN of record. Consequently, neither SSNs nor any other personal information should be released over the telephone, by FAX, or by mail as a result of a telephone request when the caller cannot provide the SSN of record.

NOTE: This does not change our basic approach to conducting business over the telephone nor does it change procedures which are initiated in the office or by institutional agreements with appropriate identification and consent. For example, some field offices (FO) have obtained signed consent statements from SSN applicants for the FO to provide their SSNs, upon issuance, to a third party via the telephone in certain time-sensitive situations such as when the number is needed by an employer. In all such cases, the FO verifies the individual's identity before a disclosure is made. Procedures for callers who provide the SSN and other appropriate identifying information are not changed.

c. Identifying the Individual of Record Calling for Himself or Herself When Caller is a Claimant/Beneficiary

A claimant/beneficiary requesting access to information about him/her via the telephone must provide the following information to establish his/her identity:

• Name,

• SSN,

• Complete mailing address, including city, state, and zip code,

• Date of birth,

• Place of birth, and

• At least one other item of information available in a system of records (such as the benefit amount or the names of other persons on the record see GN 03360.005B.3.).

See GN 03380.005B.2. for the chart containing identity verification requirements.

NOTE: If place of birth cannot be located in any SSA record, ask for another piece of information about the caller such as father's name or place of employment for the previous year.

When Caller is NOT a Claimant/Beneficiary

When the caller is not a claimant/beneficiary, he/she must provide all of the information discussed in GN 03360.005A.1. about the individual of record except the address.

2. Requests for Tax Return Information

Tax return information cannot be released over the telephone in situations where a caller is initiating contact with SSA.

However, tax information may be released by telephone in connection with a pending claim or an earnings record discrepancy case which is already in progress. This includes cases where an individual calls to question the accuracy of an earnings record.

NOTE: In these situations, the purpose of the telephone conversation is to clarify and resolve questions rather than to initiate access to tax information.

EXAMPLE: An individual who has received an earnings statement may call to inquire about the earnings shown on the statement. This subject may be discussed as necessary to resolve or clarify the question. However, if the individual asks for information about years that are not shown on the statement, this information cannot be disclosed by telephone.

3. Requests from Subject Individuals

Providing access to the individual who is the subject of the record is usually required, as long as appropriate measures are taken to ensure the caller's identity. These measures are described in GN 03340.015B.3.

An individual with a hearing or speech impairment may call SSA to request access to his or her records with the assistance of a telephone relay system operator. This request should be honored as long as the individual's identity is established. See GN 03380.005B.2. for the chart containing identity verification requirements.

(Also see GN 03340.000 for a discussion of situations in which access to records by the subject individual may be denied.)

4. Requests from Family Members

a. Requests from Parents of Minor Children

A request for information from a child's record by the child's parent is an access request which must be honored, as long as it is clear that the parent is acting on the child's behalf.

See GN 03380.005B.2. for the chart containing identity verification requirements.

NOTE: A parent's request for a child's SSN or verification of a child's SSN for income tax purposes is considered to be on the child's behalf. During tax filing periods, SSA may receive an increase in the number of telephone requests from parents for their children's SSNs or verifications of their children's SSN. The policy cited in GN 03360.005A.1.b., GN 03360.005A.1.c. and GN 03340.015B.3. pertaining to situations in which the caller does not provide the SSN of records applies to these calls.

b. Requests from Other Family Members

No personal information from a beneficiary's record (such as benefit amounts) may be disclosed to other family members without proper consent. Only general program information about Social Security benefits may be disclosed.

5. Requests from Representative Payees

As explained in GN 03316.120, information may be disclosed to a representative payee when he/she needs it to perform the duties of a payee. However, the payee's identity must first be verified.

See GN 03380.005B.2. for the chart containing identity verification requirements.

6. Requests from Legal Guardians

Legal guardians may have access to records pertaining to the individuals they represent. However, disclosure to a guardian may be made only if his/her identity and status as a guardian can be established. See GN 03380.005B.2. for the chart containing identity verification requirements.

EXAMPLE: If a call is received in a field office, and the guardianship papers are available in the office, ask the caller for the date the guardianship was effective.

7. Requests from Employers

a. SSN Information

Only a positive verification of an employee’s SSN may be given to an employer. The employer must provide the name, SSN and date of birth. If the information matches, you can advise the employer that according to our records the SSN given was assigned to the name given.

NOTE: If the name and SSN do not appear to match, do not disclose this fact, but advise the employer to have the employee contact the nearest SSA FO.

b. Other Information

Because of the difficulty of proving identity, personal information may not be disclosed to employers. Employers who need personal information about employees should be asked to submit their request in writing. See GN 03380.010B.2. for the chart containing identity verification requirements.

NOTE: Information about a potential employee should no be disclosed. Ask the employer whether or not the employee has been hired. Accept the employer's allegation and respond according to the above instructions.

8. Requests from Government Agencies

Disclosure by telephone is permitted for information needed by Federal, State, and local agencies which administer income and health maintenance programs (described in GN 03313.000 and GN 03314.000).

However, the identity of the caller must be certain. See GN 03380.010B.2. for the chart containing identity verification requirements. Generally, only local SSA FOs have sufficient familiarity with their service areas to be sure of the identity of callers from these agencies. Therefore, if a TSC receives such an inquiry, it should usually be referred to the servicing FO for a response.

Disclosure to government agencies which do not administer income or health maintenance programs should not be made by telephone.

However, in certain emergency situations in which an immediate response is required (such as in cases which could affect an individual's health or safety), the FO may disclose information by telephone pending receipt of the written request. In such situations the FO must be sure of the identity of the caller. These instances should be very rare.

9. Requests from Third Party Filers (Non-Proper Applicants)

A third party non-proper applicant who demonstrates clear intent to file is permitted to establish an appointment to file an application for benefits on behalf of a claimant.  The third party may only reschedule or cancel the claims appointment if he or she originally established that appointment.  In order to reschedule or cancel the previously established appointment, the third party must provide his or her name, telephone number and relationship to the claimant and the claimant’s name and SSN.  The information provided by the Third Party filer must exactly match the information previously documented in the 800 Number System. 

 NOTE: Individuals present with the claimant at the time of filing merely to assist the claimant in filing an application are not third party filers. These individuals are considered helpers and may not reschedule or cancel the previously established appointment. See GN 03340.005B.4 for information about these helpers.

B. Procedure

When a person calls SSA to obtain personal information from our records, take steps to verify the person's identity.

1. Caller is an SSA Employee from Another Office

(Personal information may be freely disclosed by telephone within SSA based on “need to know,” i.e., when an employee needs the information to perform his or her duties.)

If the person requesting information is an SSA employee whom you know, and you are certain of his or her identity, disclose the information without further development.

If you do not know the caller, verify his or her identity using the SSA Employee Identification Data Base (SEID), which is described in MSOM QUERIES 005.010 . Once the identifying data has been verified by SEID, release the information.

If the data does not match the information on the system, but the caller still maintains that he or she is an SSA employee, ask for the name and telephone number of the caller's supervisor and call back. Establish the identity of the supervisor using the SEID. (If it is established that the employee's name was omitted from the SEID, the employee's supervisor should take action to get the SEID corrected. See GN 03380.010B.2. for the chart containing identity verification requirements.)

Refer any suspected bogus calls to your supervisor for necessary action.

2. The Caller is Not an SSA Employee

a. Verifying Identity

In cases where the caller is not an SSA employee, verify identity using information available in an SSA system of records. (The Client Identification screen was designed to contain data which may be used for this purpose. A list of the required identifying data in various situations is given in GN 03360.005B.4. See also GN 03360.005A.1.c. See GN 03380.010B.2. for the chart containing identity verification requirements.)

After checking the data provided by the caller against SSA's records, decide whether your have satisfactory verification of the caller's identity.

• If the identity is established, release the requested information.

• If you cannot verify identity, tell the caller that the written consent of the subject individual is necessary prior to disclosure.

NOTE: Cases in which disclosure cannot be made by phone and an immediate response is needed should be referred by a TSC to the local FO.

b. Exceptions

Do not disclose over the telephone if there is any doubt about whether disclosure is appropriate, or if sensitive information is involved. Instead, have the requester submit the request in writing.

EXAMPLES: Medical records and tax return information are considered sensitive information which cannot be released by telephone.

3. Data Used to Verify Identity

The specific types of information you may use to verify a caller's identity will vary somewhat, depending on what part of SSA's records you will have to access. In all cases, there are certain mandatory items which a caller must be able to provide. Ask for as much additional data as you need to verify identity.

Additional data may include (when applicable) the caller's or the beneficiary's:

• Date of entitlement to benefits

• Amount of benefits

• Mother's maiden name

• Last employer

• Method of payment (i.e., check or direct deposit)

In cases where you ask the caller to provide a:

• Date of birth — the month and day of birth provided by the caller must be an exact match; there is a 2 year tolerance for the year of birth.

• Place of birth — the State or Country provided by the caller must be an exact match; request the city or town only when a city or town appears on the Numident. The city or town does not have to match in order to satisfy this requirement. If the Numident does not contain a city or town, do not request it.

See RM 00499.004 for a list of standard foreign country abbreviation codes.

4. Situations Requiring Identification

Follow the instructions below for situations requiring identification of the caller.

a. The Caller is the Individual of Record Calling for Himself or Herself

If the caller is a beneficiary or claimant, ask for the name, SSN, address, date of birth, and place of birth. Also ask for at least one other item of information available in the system of records (such as the benefit amount or the names of other persons on the record).

If the caller is not a beneficiary or claimant, ask for the name, SSN, date of birth and place of birth. Also ask for at least one other piece of information available in the system of records (such as the name of the last employer, or mother's maiden name). See GN 03380.005B.2. for the chart containing identity verification requirements.

b. The Caller is a Parent Calling on Behalf of a Minor Child

Access to the record may only be provided if the parent is calling on behalf of the minor child (see GN 03340.025A.).

To identify the caller, ask for the name, SSN, address, date of birth and place of birth (the address does not have to be verified).

To identify the child:

• If the child is a beneficiary, ask for the name, SSN, address, date of birth and place of birth, along with one other piece of information.

• If the child is not a beneficiary, ask for the name, SSN, date of birth and place of birth, along with one other piece of information.

See GN 03380.005B.2. for the chart containing identity verification requirements.

c. The Caller is a Representative Payee

REMINDER: Disclosure is limited to information needed to perform the payee's responsibilities).

• Individual Payee

To identify the payee and the beneficiary, ask for the name, SSN, address, date of birth and place of birth, along with one other piece of information for both the payee and the beneficiary.

• Organizational Payee

To identify the caller representing an organizational payee (e.g. nursing home or social agency), ask for the name of the organization, address (physical location including zip code), Employer Identification Number, and the identifying information shown in GN 03360.005B.4.c., first bullet, for the beneficiary.

See GN 03380.010B.2. for the chart containing identity verification requirements.

d. The Caller is a Third Party Calling for an Individual Who is Present and Gives Oral Permission (see GN 03340.005B.4.)

Identification of the caller is unnecessary. Verify from the subject individual that he or she gives oral permission to receiving assistance in obtaining access to his or her records.

To identify the subject individual, ask for the name, SSN, address, date of birth and place of birth, along with one other piece of information.

e. The Caller is an Authorized Representative (Attorney or Non-attorney)

To identify the caller/representative, verify that the subject individual has authorized this representative (by obtaining a query or accessing the Form SSA-1696 (Appointment of Representative) if it is available). No further identification is necessary.

To identify the beneficiary/claimant, ask for the name, SSN, address, date of birth and place of birth, along with one other piece of information.

See GN 03380.010B.2. for the chart containing identity verification requirements.

f. The Caller is Working for Another Federal, State, or Local Government Agency

Disclose information only to certain government agencies. If the agency in question meets the requirements outlined in GN 03313.000 and GN 03314.000, disclose information if you know the individual and are certain of his or her identity. If the caller's identity is unknown or uncertain, verify by calling back the agency using a listed phone number and/or the name of a second employee of the agency. See GN 03380.010B.2. for the chart containing identity verification requirements.

g. The Caller is a Third Party Other Than One of the Parties Listed Above

Tell the caller that the written consent of the subject individual is necessary prior to disclosure.

REMINDER: Disclosure of personal information by telephone to a third party is normally not permitted in any other situations.