Please help quick! We received our first tape from the Dept of Human Services for Child Support social security matches for nonsupport parents. On the report that is generated to send back to them it identifies the customer, account number, account balance, social security number.

Although my state permits supplying the Human Service Dept with this information, does Privacy Regulation? and do I need something additional in our contract with the HS Dept?

Thank so much for your opinions

Requests are mine not my employer

Refer to paragraph(e)(7) of section .15 of the privacy regulation for your regulatory agency. You are permitted to share this information because it is required by state law. I do not think any specific contract language is required. If you have the ability to make a change, you might want to include language to indicate that they will only use the information for the purpose for which it was intended and that they will take appropriate measures to safeguard the information.

Here is a link to Reg P of the Federal Reserve that is found here on the the BOL web site.

http://www.bankersonline.com/regs/216/216-15.html

Reg P Section 216.15(a)(7) allows you to release the information to the state. I don't know about your state, but ours was good to point out that they'd complied with all applicable laws to allow us to give them the information.

Oops! Meant to say paragraph (a)(7) of section .15.

My compliance association asked this of the OCC, because our state, NY, gives us the option to either get the list from them and send back our matches (which sounds like your mode) or to download our database to them so they can pick out the matches. The consensus of opinion from the OCC was that since we were complying with a law, we were not in violation of Privacy by sending them the matches -- but we would be (maybe, possibly) in violation if we choice the option to send the entire database and let them run it.
Hope this helps.

Thank you all very much. I feel much better!