Though not necessarily embodied in a law or regulation, federal agency
practices with window envelopes illustrate the cavalier attitude bureaucrats and
agencies may take toward personal information, and how this may threaten privacy
or other important interests.
Until the practice was exposed as a problem, federal agencies including the
Social Security Administration routinely exhibit people's
personal information (beyond name and address) through the
windows of envelopes. This needlessly creates a risk that
the mailing of checks and other information will expose recipients
to identity
fraud or invasions of privacy.
Federal agency explanations for this were lame. The Financial Management
Service in the U.S. Department of Treasury said that social security numbers had to
be displayed so that checks could be manually processed during the two weeks between
when they were printed and when they were mailed. FMS explained that social security
numbers "are in no way compromised during transit as only government employees
(FMS and U.S. Postal Service) and the recipients handle the envelopes." As if
fraudsters obey the laws against tampering with mail.
Likewise, the Defense Privacy Board in the Department of Defense has opined that
the appearance of the Social Security number in a window envelope "does not constitute
a disclosure as contemplated by the Privacy Act. Prior to delivery to the recipient,
the only likely disclosure is to personnel of the postal service . . . ."
Links:
The
Social Security Number Confidentiality Act of 2000 (H.R. 3218)
Window Envelopes
and Social Security Number Visibility, Q&A Web page, Financial Management
Service, Department of the Treasury (updated February 2, 2001)
The Appearance of the Social Security Number in the Window of an Envelope Containing
Record Information Does Not Constitute a Disclosure, Opinion of Defense Privacy
Board, Department of Defense (September 23, 1998)
Comments? comments@privacilla.org
(Subject: Envelopes)
[updated 04/17/02]
