State Death Match - Manual

Privacy Act Statement for Collection of Death Match Information

The Privacy Act (5 U.S.C. 552a(a)(3) and (b)(3) and Social Security Administration’s (SSA) disclosure regulation (20CFR part 401) permit SSA to disclose information for routine uses; i.e., disclose information about individuals without their consents for purposes compatible with the purpose for which the information is collected. Section 401.150 of the regulation (20 CFR 401.150) allows SSA to disclose information under a routine use to administer SSA programs. The information secured under the death match allows SSA to receive timely death information from the States that will result in timely termination of Social Security benefits when Social Security beneficiaries die.

SSA has established a routine use under the Privacy Act that permits the Agency to verify Social Security numbers (SSN) for State bureaus of vital statistics (BVS) for individuals for whom the BVS is preparing an electronic death report. SSA must comply with the Privacy Act when verifying the SSNs in these cases because at the time the SSN verification are performed SSA records do not identify the individuals to whom the SSNs have been assigned as being deceased. Since the individuals are dead, there are no adverse effects on the individual rights. In the event that an SSN verification may be inadvertently provided for an individual who is alive, the individual’s rights would be protected through an agreement with the State BVS that restricts their use or disclosure of such information.

Since both under the Freedom of Information Act and the Privacy Act, privacy rights end at death, a Privacy Act Statement is not necessary for the State Death Match, IEDR, Online Verification of the Social Security Number in the State Death Registration Process, nor in the existing Death Match process.