If an individual authorizes disclosure of personal information, we should generally assume that that person knows what is in the file. This is also true of the parent of a minor child or legal guardian who is acting on behalf of that person. In these cases, personal data do not have to be deleted from the file.

However, if embarrassment or harm could be caused by disclosing certain material in the file to a third party, consider discussing the material with the person authorizing release before disclosing the information.

Claims material relating to another person, such as a number holder's (NH) spouse or child, must be considered to be in a separate file, even though it is physicially located in the NH's claims folder.

EXAMPLE: Authorization by an NH to release information about himself would not apply to information relating to his wife.

Release of a record without authorization may be done under the exceptions of the PA and, in very limited circumstances, under the FOIA. The only personal information that should be released is that which is relevant to the issue at hand.

EXAMPLE: If an issue concerns only the NH, any personal data concerning other persons in the file should be deleted.

See GN 03316.105, GN 03316.110, GN 03316.115, GN 03316.120, GN 03316.125 concerning:

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  the NH's right to information and

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  disclosures to applicants, claimants, representative payees and their authorized representatives.