Social Security

This bulletin provides guidance regarding acceptable methods of securing paper claim files and CDs containing electronic claim files or digital recordings for travel dockets at remote hearing sites. All employees must make every reasonable effort to secure and lock PII during transit and while outside secure SSA space.

Where paper files still exist, SSA employees must transport them to the remote sites. With electronic claim files the physical transferring of materials containing Personally Identifiable Information (PII) is reduced due to the connectivity to the SSA’s data network at some Permanent Remote Sites; however, at Temporary Remote Sites where there is no connectivity to the SSA network SSA employees must transport the electronic file CDs and the hearings record CDs to and from the site. The Chief Information Officer (CIO) specified requirements for safeguarding all materials in his message dated March 5, 2007, entitled “Procedures for Safeguarding Personally Identifiable Information (PII) While in Transit or Outside of Secure SSA Space.” http://eis.ba.ssa.gov/ssasso/procedure_for_safeguarding_transit.htm

A. Securing PII When Transporting Files to a Remote Hearing Site:
1. Paper files
   1. ALJs may transport paper files in boxes and crates. The boxes or crates must have lids that close to conceal PII and should be sealed with tape and initialed in such a manner that tampering would be evident. If transporting by vehicle, the sealed boxes or crates must be secured in the locked trunk or out of view in the locked vehicle.
   2. ALJs and staff may ship paper files by US Mail so long as USPS tracking is employed.
   3. ALJs and staff may ship paper files by Fed Ex only in accordance with AIMS guidelines. See http://ssahost.ba.ssa.gov/aims/MRM/M0203.htm
   4. ALJs may entrust sealed boxes of paper files to a Verbatim Hearing Recording contractor (VHR) for shipment or mailing to the Hearing Office.
   5. ALJs may not leave files with hotel personnel for pick up by Fed Ex, UPS or the USPS for return to the Hearing Office. However, as stated in d. the VHR may take the files to the U.S. Post Office.
2. CDs of Electronic files
• ALJs should personally transport CDs in a locked briefcase or other locking container.

B. Securing Agency Files and Equipment Containing PII While at a Temporary Remote Site:
1. The ALJ may store equipment and properly sealed and initialed (see A.1.a.) boxes or crates containing files in the ALJ’s locked vehicle.
a. The trunk is preferable.
b. If the vehicle does not have a trunk, or the trunk cannot be used, the ALJ must take care to ensure that the equipment and/or the properly sealed and initialed (see A.1.a.) boxes or crates are not in plain view.
2. If the TRS is a hotel:
a. ALJs should arrange to store equipment and properly sealed and initialed (see A.1.a.) boxes or crates containing files in the hotel secure room or other space where access is limited to authorized hotel staff only,
b. ALJs should utilize the hotel safe for small items such as CDs.
c. ALJs should only use the hotel hearing room or sleeping room for storage as a last resort.
3. If the TRS is in a Federal building, such as a court house, post office, etc.:
• The ALJ should store equipment and properly sealed and initialed (see A.1.a.) boxes or crates containing files in a locked room, provided that the room is reserved exclusively for our use and guard service or intrusion detection is provided on site.