The routine-use regulations for totalization became effective January 7, 1980. From
that date, any information in specific systems of records may be disclosed to a foreign
country with which the United States has a totalization agreement if the information
is required to adjudicate a claim filed under the agreement. To be considered “filed under an agreement” for consent purposes, a claim must be made on an application form specifically designed
to take claims under an agreement (see GN 01704.425) or on a national application of the United States or a country with which an agreement
is in effect, if that application was filed on or after the effective date of the
agreement and indicates coverage under the agreement.
If one of these forms has been filed, information needed by the foreign country pertaining
to any individual listed on that application for whom benefits are being claimed may
be disclosed. Consent statement(s) from the listed individuals is (are) not required.
SSA may disclose information from the application itself, as well as information from
any of the approved systems of records not only under the SSN on which the totalization
claim was filed, but also under any related SSN. However, SSA must be satisfied a
claim has been filed under an agreement before disclosing information. Either a copy
of the application or a statement from the foreign agency that a claim has been filed
under the Social Security totalization agreement between the United States and its
country and that the information being requested is needed to process that claim will
be sufficient. Assume foreign agencies request U.S. ERS only if such a claim has been
filed.