3-5.5 Accounting of Disclosures

1. Requirement. Custodians must keep an accurate accounting of every disclosure of information about an individual covered by a system of records, even if the disclosure is made at the individual’s request. The only exceptions are as follows:
1. Publicly available information. See section 4-4.
2. Information disclosed to Postal Service employees or contractors in the performance of their Postal Service duties.
3. Information disclosed to the individual to whom the information pertains.
2. Request for Accounting of Disclosures. Individuals may request that the Postal Service provide its accounting of disclosures of records relating to themselves. The request must be made to the facility where the record is kept, and must clearly identify the requester and the system of records. Requests for accountings of disclosures pursuant to a computer match must be addressed to the Records Office manager at the address in section 1-4.2.5.
3. Response. The custodian must notify the requester within 30 days (excluding weekends and federal holidays) of receipt of the request whether a record of disclosures exists. If such a record exists, the custodian must give the requester the disclosure information unless an exception under section 3-4.1b(6) applies.
4. Disclosure Formats. There are four formats for an accounting of disclosures:
1. General Format Guidance. The format of an accounting of a disclosure is usually a memorandum to the file (see suggested format in Exhibit 3-5.5), a copy of the correspondence transmitting the disclosed information, a log, or other listing, and must show:
1. The date, nature (such as employee accident record folder review), and purpose (such as legal proceeding) of the disclosure.
2. The name and address of the agency or person to whom the disclosure was made.
2. Official Personnel Folders. Use PS Form 6100-B, OPF Disclosure Accounting Form, to account for disclosure of information in OPFs to law enforcement officials. Use PS Form 6100-A, OPF Disclosure Accounting Form, to account for all other disclosures. For OPFs converted to electronic Official Personnel Folder (eOPF), a system-generated accounting of disclosure may be used in lieu of PS Form 6100-A or PS Form 6100-B.
3. Union Representatives. Except for disclosures of OPF information, use PS Form 6105, Disclosure of Information About Employees to Collective Bargaining Agents, to account for disclosures to collective bargaining agents.
4. Inspection Service. Use PS Form 2099, Inspection Service Disclosure Record, to document disclosure of investigative information about individuals.
5. Filing and Retention. The disclosure form must be filed, cross–indexed, or otherwise associated with the disclosed record, so that a complete accounting of disclosures can be constructed. The accounting must be kept for 5 years or the life of the disclosed record, whichever is longer.

Exhibit 3-5.5 

Suggested Format for Memo on Disclosure