ACCOUNTING OF DISCLOSURES OF RECORDS MADE TO PERSONS OR ENTITIES OUTSIDE THE CENTRAL INTELLIGENCE AGENCY (CIA)

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84B00890R000600140015-3
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 15
• Document Creation Date: December 16, 2016
• Document Release Date: July 21, 2005
• Sequence Number: 15
• Publication Date: June 3, 1981
• Content Type: MEMO

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S ROUTING AND RECORD SHEET
SUBJECT: (Optional)
Accounting of Disclosures Outside CIA
FROM: E ENSION
NO.
George Darnell, FOIA/OD
2D00 HQS
DATE
TO: (Officer designation, room number, and
building)
DATE
COMMENTS (Number each comment to show from whom
RECEIVED
FORW
to whom. Draw a line across column after each comment.)
A/EO/DDA
BX-4
2.
3.
4.
5.
6.
7.
8.
9.
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15.
STAT
FORM 61 0 USE PREVIOUS
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 Approved Fo lease 2005/08/02 : CIA-RDP84B008 000600140015-3 DD/A Registry
SUBJECT: Accounting of Disclosures of Records Made to Persons
or Entities Outside the Central Intelligence Agency
(CIA)
REFERENCE: Memo fm OGC dtd 26 May 81, same subject (OGC 81-04296)
1. The Office of Data Processing (ODP) maintains five systems
of records subject to the Privacy Act and reported in the Federal
Register. Contractual relationships with hardware and software
vendors providing services to CIA make it necessary for us to
disclose information contained in these systems to contractors'
representatives. ODP does not currently keep any purposeful or
complete accounting of these disclosures. To do so would entail an
unwarranted burden in carrying out legitimate administrative
correspondence with contractors for the reasons stated below.
2. ODP makes no disclosures outside of CIA from two of its
Privacy Systems, the ODP Training Records System and ODP's Computer
Access Files. The first of these systems is used to keep track of
the Agency-sponsored training completed by ODP employees. It is a
computerized ready-reference data base used for local administra-
tive functions in ODP. No disclosures outside of CIA are necessary
or proper because the Office of Training and Education maintains
the official record for each employee.
3. The second system, the Computer Access File, records the
User Identification (USERID) and Password of every person who has
access to an ODP computer through a terminal. This information is
used for CIA internal security management and is therefore not
disclosed outside CIA.
4. Information concerning employees who are working or plan
to work for a contractor, e.g., IBM, TRW, CSC, etc. on an ODP
contract, is maintained in the three remaining Privacy Systems.
The first of these, the Applications Tracking System, keeps track
of, among other things, the hours expended by staff or contractor
employees on an ODP project. This data base is used as an
authority file for charging ODP customers through a Project
Activity Report (PAR) for the man-hours expended on an ODP project
done for them. It is also used to verify the invoices of con-
tractors for billed man-hours. This verification frequently
requires a Contracting Officer's Technical Representative (COTR) to
discuss with a Contractor's Representative the contents of this
system of records regarding the hours reported by a contractor's
employee. Because there are several COTR's in ODP with authorized
access to the system, no accounting is kept of such disclosures.
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P j,
To do so'would require a single point of contact who would record
each disclosure in a manual or computer-based log. This would not
be impossible, but it seems hardly warranted by the type of
disclosure concerned.
5. The second file from which disclosures are made to
contractors, again by COTR's and also by ODP's Security Officer and
Assistant, is ODP's Security Clearance Records. This file keeps
track of the security clearances and compartmented accesses
requested, in process, or granted to contractor employees.
Frequent dialogue occurs between ODP employees and contractors'
representatives about the status of clearances requested for
contractors' employees. Again, no accounting is kept of these
discussions. To gain the control necessary to do so would require
that the Security Officer be the single person authorized to
discuss clearances with contractors. Such a bottleneck would
hamper relations with contractors.
6. The third ODP file from which disclosures are made to
contractors, usually only by the Security Officer or Assistant, is
ODP's Computer Room Access File. This file keeps track of which
employees, Agency and contractor, have been authorized to enter ODP
computer rooms. This information is used to request Special Badge
Indicators from the Office of Security and to provide the computer
centers with a list of authorized personnel. Contractors occa-
sionally want to know whether one of their employees has access to
a particular computer center. (This is true especially of computer
maintenance personnel.) ODP has not placed any restrictions on who
in ODP can provide a contractor with this information. Such re-
striction would be prerequisite to establishing an accurate
accounting of this type of disclosure.
7. Without a clear definition of what constitutes a
disclosure, ODP would find it difficult to decide what should be
accounted for. ODP has taken the view that the information being
discussed (disclosed) with contractors in the situations described
above is necessary to the proper conduct of contractual business
and therefore not subject to the accounting provisions of the
Privacy Act. ODP's line of reasoning has been that the contractor,
through a contractual relationship with CIA, becomes an extension
of the Agency. Therefore, routine disclosures to contractor
employees do not require accounting under the Privacy Act.
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 mNNIVVmu Ful IGaaG LVV)IVOIVC . \..I/1-IZVrO' VVO VVOVV 14VV IJ-J
ROUTING AND RECORD SHEET
STPJ
Deputy Director of Finance
1212 Key Bldg.
TO: (Officer designation, room number, and
building)
i Deputy Director tor
Administration
7D24
OFFICER'S
INITIALS
2 June 1981
81-1/3(v SJ
COMMENTS (Number each comment to show from whom
to whom. Draw a line across column after each comment.)
Attached per your request is a
blind memo representing OF
response to OGC Memo 81-04296
dated 26 May 1981
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SUBJECT: Accounting of Disclosures of Records made to Persons or
Entities Outside CIA
REFERENCE: OGC 81-04296, dated 26 May 1981
1. The Office of Finance maintains only informal temporary accountings
of disclosures of formal requests submitted to the Agency pursuant to E.O. 11652,
the FOIA, and the PA, since paragraph 7c designated IPS (now IPD) as the
component of record for these requests.
2. In addition to the formal requests for disclosure under the acts noted,
Office of Finance routinely discloses information outside CIA on employees,
former employees, and other individuals in a number of ways:
a. Annual submission to Internal Revenue Service (both Federal
and State) on wages paid and taxes withheld. (Withholdings are
based on W-4 signed by employee and employee is provided copies of
W- 2.)
b. Register of Separation and Transfers - Standard Form 2807 and
Individual Retirement Record - Standard Form 2806: (Forms used to
transfer retirement credits to the Civil Service Retirement System
when an employee resigns from the Agency or retires under CS. See
Attachment 1 for sample.)
c. Request for Wage and Separation Information: (Form used by
State unemployment offices to verify claimants record of employment.
PA release authorization signed by claimant usually accompanies this
form. See Attachment 2 for sample.)
d. Request for Information from Employer - Form 3242 (Form used
by IRS to locate persons. Employee not aware of this request and/or
disclosure. See Attachment 3 for sample.)
e. Request for Recovery of Debt Due the United States - Form 2805
(Form used to collect indebtedness of former employees. Employees
consent is not required. See Attachment 4 for sample.)
3. The above types of routine disclosures are intended to be representative
and do not include all made by Office of Finance to outside agencies. We oc-
casionally have court actions (Notice of Levy on Wages, Salary, or Other Income),
requests from Social Security Administration on eligibility for social security
and other such official inquiries that result in disclosure of information.
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Our disclosures for the most part follow the requirements established by the
Federal Personnel Manual, Department of Labor, Justice, or other federal entities.
4. Records of disclosures vary. Copies of W-2's are kept in a central file
for three years. A computer printout is also available. Form 2807's are main-
tained in a central file -as are requests from State unemployment offices and Form
3242's and Form 2805's. Copies are not filed in the employees payroll file
because'of the extra volume of work and paper that would be generated. We be-
lieve that each of the forms sent out of this office accurately records (1) the
date, nature, and purpose of such disclosure and (2) the name and address of
each person or entity to whom such a disclosure is made.
5. On the question of accounting for disclosures, we do not believe that
an automated system would be worth the cost involved to establish and maintain.
Given enough time, I believe we can account within reason for disclosures on
any one individual in keeping with the spirit of the law.
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 STANDARD FORM NO . Prove Release 2085/08/02 IA- QP84BO~MOR000600140015-3NSN 7540-00-634-4257
e9Ister of Separations
July 1900 Previous Editions Not Usable
FPM SUPPLEMENT 831-1 and Transfers
2807-104 Civil Service Retirement System :sue
Agency Date Page No.
Bureau or Reporting Unit
Location
Payroll Office No.*
CURRENT YEAR
TOTAL RETIREMENT
DATE OF SEPARATION
NAME AND DATE OF BIRTH
RETIREMENT DEDUCTIONS
DEDUCTIONS TO CREDIT
AND REMARKS, IF ANY
(for agency use only)
OF EMPLOYEES
(1)
(2)
(3)
(4)
$
$
Page Totals
Totals Brought Forward from Page ----------
Accumulated Totals to Date
INSTRUCTIONS: One copy of this register must accompany 2806's transmitted to the Office of Personnel Management and one copy sent to
agency retirement officer by bureau or reporting unit.
*Give payroll office number of SUBMITTING office.
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Subchapter S23. Register of Separations and Transfers
(SF 2807)
S23-1. PURPOSE
a. Use by Commission. Standard Form
2807, I.egister of Separations and Transfers,
serves to authenticate the Standard Forms
2806, Individual Retirement Record, sum-
marized therein and attached thereto for trans-
mittal to the Commission. Together with
other fiscal and accounting data available to
the Commission, the Standard Form 2807. is
an essential document controlling retirement
moneys.
b. Use by agency. (1) A copy of Standard
Form 2807 is the document used by an agency
to retain summarized fiscal data when, upon
separation of an employee, the Standard Form
(or Forms) 2806 is released to the Commission
or, upon intra-agency transfer, to another
reporting office in the same agency. The cur-
rent year and accumulative total retirement
deductions on Standard Form 2807, in turn,
iecome part of the basis upon which the agency
or reporting office prepares its annual summary
of retirement fund transactions, which is
re luired as explained in subchapter S25.
(2) It is preferable that as many individual
re ?ords as possible be summarized on one
Si andard Form 2807. However, release of one
Siandard Form 2806 or of a few is not delayed
a,vaiting other separations or transfers, nor is
a group of individual records delayed because of
inability to complete and transmit one or more
records.
S23-2. PREPARATION AND
MAINTENANCE
a. Preparation and number of copies.
Standard Form 2807 is prepared as shown in
appendix A. If maintenance of Standard Form
2806 is centralized, Standard Form 2807 is
prepared in duplicate. If maintenance is
decentralized, Standard Form 2807 is prepared
in triplicate.
b. Maintenance and series designations.
Two series of Standard Form 2807 are main-
tained by reporting offices in agencies which
keep Standard Form 2806 on a decentralized
basis-one series, denoted "CSC" to cover
Form 2806 released to the Commission when
an employee is separated, and the other series,
denoted "IA" to cover forms 2806 released when
employees move to another office in the same
agency. Agencies which maintain records cen-
trally and have only one reporting office need
only the CSC series.
c. Sequence numbers. Each Standard Form
2807, at the time it is released, is assigned
the next consecutive number in its series. The
assigned number is preceded by the number of
the current calendar year, e.g., CSC 78-1,
CSC 78-2. On the first business day of each
calendar year, a new sequence of numbers,
beginning with 1, will be started for both the
CSC and IA series., The current calendar
year series is discontinued at the close of
business December 31. The calendar year
in which the Standard Form 2807 is released
will determine the calendar year number used
on the Standard Form 2807, regardless of the
date of separation, except for those Standard
Forms 2807 necessary to correct errors made
on Standard Forms 2806 released and discovered
before the preparation of Standard Form
2807-2, Annual Summary of Retirement Fund
Transactions.
S23-3. DISPOSITION
a. Accompanies Standard Form 2806 or
2806-1. Every Standard Form 2806, or Stand-
Inst. 27
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and Form 2806-1 (Notice of Correction of Indi-
vidual Retirement Record) which corrects fiscal
(not service history) data, released by an
agency or reporting office is listed on and
accompanied by a Standard Form 2807.
Neither document is accepted by the Commis-
sion without the other nor should the gaining
office, in the case of an intraagency transfer,
accept one document without the other.
b. Use of copies. Agencies which keep cen-
tralized retirement records retain the duplicate
SF 2807. In* agencies which have decentral-
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ized retirement recordkeeping, the reporting
offices forward the duplicate to the agency
retirement officer (or other central reporting
point designated) and retain the triplicate.
The retained copies are used as a medium
of posting to the retirement control accounts,
and also in preparing the annual summary of
retirement fund transactions. In decentral-
ized agencies, the duplicate in possession of
the retirement officer is used to reconcile the
annual summaries submitted by the reporting
offices.
Inst. 27
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RELEASE AUTHORIZATION
I agree to any request by the State agency, from which I have claimed unemployment compensa-
tion, for. information from my former Federal employing agency or from military authorities,
which is required by law in connection with my claim for unemployment compensation. I
consent to the furnishing of the requested information by such agency irrespective of whether the
Privacy Act of 1974 (5 U.S.C. 552a) would preclude the release of the information without my
consent.
'n'1Lt {J IU rr ]A-
1~ : -LIr
r? ~~'Srnnature oi'Claimant =?~
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Subchapter 519. Loans, Indebtedness, and Setoffs
S19-1. LOANS Al\~D PRIVATE I1~~EBTED-
I~'ESS
An employee or annuitant may not borrow
from the fund or assign money credited to
his or her account e:s security for a loan or
for any other purpose. Lump-sum credit or
annuit3- is generally not subject to execution,
levy, attachment, garnishment or other legal
process, except under certain conditions in-
volving nonpati-ment of child support and ali-
mony. The Commission is not authorized to
induce an annuitant to satisfy- a claim of a
private creditor, or to arrange for the collection
of a private indebtedness from annuity
payments.
S29-2. INDEBTEDNESS TO THE UNITED
STATES
a. When setoff may be requested. Money
payable from the Fund may be set off to effect
recovery of any valid debt to the United States
-cif all of the following conditions are met.
(1) The employee has been separated.
(2) The debt amounts to $25 or more.
(3) The creditor agency has exhausted all
other means of recovery=. (VPhen a person is
indebted to his or her employing agency, the
deb``t should be recovered from the final salary
check and/or terminal leave payment, if any.
If a person is indebted to an agency other than
the one in which he or she is employed, arrange-
ments should be made with the employing
agency to recover the debt from an3T salary pay-
ments as they become due.)
(4) The creditor agency has given the em-
ployee an opportunity to request reconsidera-
tion of the collection, including waiver and/or
compromise, as applicable.
Reconsideration involves the process of-
(a) revie.~ving the correctness of the amount
charged against the debtor's funds and the
existence of an indebtedness;
InsL 28
l\ovember 22, 1978
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(b) making a determination whether he or
she is entitled to any relief (e.g. waiver) under
applicable laws a.nd regulations; and
(c) negotiating with the debtor-
(i) to make any reduction in the amount
- of the indebtedness to which he or she
may be entitled, or
(ii) the amount of the installment, for an-
nuitants whose monthly benefit must
be reduced.F
b. Overpayments which are not recoverable.
Unliquidated unearned (advanced) annual and
sick leave does not constitute a valid indebted-
ness when the employee is separated by death or
retirement for disability, or when the employee
is unable to return to dut3* because of disability
evidenced by an acceptable medical certificate.
Also, no recovery need be made for illegal
payment of dual pay ithin sir years from the last date of
any period involved.
S19-3. AVAILABILITY OF FiTNDS FOR
SETOFF
Money payable from the fund may be
available for setoff as follows:
(1) Any annuity payment due the former
employee is available. The debt of a deceased
employee may not be recovered from annuity
payable to a spouse or children.
(2) If the former employee has less than five
years of civilian service his or her lump-sum
credit is available.
(3) If the former employee has more than
five years of civilian service, the lump-sum
credit is available if and when he or she applies
for refund. If he or she does not apply for
refund, the annuity payments are available
when he or she establishes eligibility- for annuity=.
(4) Upon the death of an employee or former
employee, the lump-sum credit is available
for setoff.
 88 - Approvedar Release 2
519-4. SETOFF PROCEDURE
~~7CIA-RDP84B~90R000600140015-3
dividual is entitled to a lump sum and the
The follo~>ing procedure must be observed
in requesting setoff of money payable from the
fund:
(1) Request for Recovery of Debt Due the
United States, Standard Form 2805, must be
submitted in duplicate to the Commission by
the agency requesting setoff -together with
form BRI 49-413A, Recertification of Request
for Recovery of Debt Due the United States.
Where a debt has been pursued to judgment,
the Commission will honor an agency's request
without? form BRI 49-413A, but a copy of the
court order should be attached to the SF 2805.
The Commission is aware that agencies will
not? be able to obtain the debtor's consent. to
the collection in every case; therefore, Govem-
ment? claims will be honored upon receipt of the
agency's recertification. The individual's con-
sent is not a requirement; however, where the
reconsideration process has resulted in a com-
promise which specifies recovery of less than
the total debt, or in the case of an annuitant,
a. specific monthly installment is agreed upon,
agencies should obtain the debtor's consent to
the agreement and submit a copy to the
Commission.E
(2) If the debtor is an employee of the agency,
Standard Form 2805 -hand form BRI 49-
413AF should be fon~~arded to the Commission
when the employee is separated. Preferabl3>, the
request for setoff should be made when the
Individual Retirement Record, Standard Form
2806, is fo~arded; however, the retirement
record should not be withheld pending sub-
mission of a request for seto$. -~If s, debt exists
end the individual's SF 2806 is submitted with-
out the SF 2805 and BRI 49-413A, a notation
should be made either in column 8 (RE-
1\~ARgS) under FISCAL RECORD or on an
attachment to the SF 2806 indicating a debt
is in existence and the amount, if kno~;-n. In such
cases, agencies will be allowed 60 days to submit
the SF 2805 and BRI 49-413A. Where the in-
Inst. 28
1\ovember 22, 1978
indebtedness is being litigated, the Commission
will hold the disputed amount until the outcome
is decided.E- If the debtor is eligible for annuity
and if the amount of indebtedness is greater
than the monthly acuity, -the Commission
has determined, as s matter of policy, that
debts and overpayments will be recovered from
the civil service annuitant in installments of no
more than 25 percent of the annuitant's monthly
benefit? if the recovery can be made in 36 install-
ments. 'With the a~uitant's consent, a higher
percentage of the monthly benefit will be taken,
if necessary, to liquidate the indebtedness in
36 installments or less. Where the total debt is
ver3- large as compared with the total monthly
annuity, or in cases of severe financial hardship,
a longer period will be taken to recover the
entire debt. -
Agencies seeking recovery against au annu-
itant should, therefore, specify the amount of
the installment unless they are willing to accept
the rate established by the Commission. In
situations where there has been no agreement
between the. debtor and the agency, if the an-
nuitant complains about the amount of the
installment withheld, collection will be sus-
pended, and he or she will be referred to the
requesting agency to come to an aZ~reement on
the installment to be collected. When a copy of
the resulting agreement is submitted to the
Commission, recovery will be resumed.F
(3) If the debtor is currently an employee
of an agency other than the creditor agency, a
statement must accompany the Standard Form
2805, showing in detail what attempts have
been made to collect the debt through the
employing agency.
(4) When a claim is filed for recovery of e
pay overpayment, regardless of the reason for
the overpayment, the amount of indebtedness
tq be reported on Standard Form 2805. is the
unliquidated balance of the gross pay over-
payment, including any withholding tax, re-
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' tirement. deductions, and other deductions
as applicable.
(5) An SF 2805 filed with the Commission
remains valid and in effect until the amount
available .from the Fund has been fully recov-
ered, or until the Commission is notified by the
agency requesting seto$ that the indebtedness
no longer exists. Therefore, if an indebtedness
for which an SF 2805 has been filed becomes
completely or partially liquidated in some way
other than by setoff from the Fund, the Com-
mission should be notified. Failure to notify
the Commission when an indebtedness has
been liquidated or reduced may result
in s. setoff from the Fund for an indebtedness
that no longer exists and Rill require adjustment
by the agency.
S19-S. C0;11?11ISSIOi~ ACTIO;~ ON SETOFF
CI..AIAZS
a. 6cknowledgment and payment. The
Commission uses the duplicate copy of Standard
Form 2805 to acknowledge receipt of the claim
and to advise the agency whether funds are
available for setoff. Sfihen, and to the extent
that funds are available, the Commission
makes the setoff, and a check covering the
amount involved, with sufficient information
thereon to enable the agency to apply the
proceeds properly, is forwarded to the agency
at the address indicated on Standard Form
2805.
b. Employee protests and appeals. The
Commission does not review either the validity
or the amount of an indebtedness certified by
the reporting agency.
InaL 28
l~ovember 22, 1978
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