Recordings of Service Observations

Social Security Administration

Notice of System of Records

Required by the Privacy Act of 1974, As Amended

System number:  60-0362

System name:  Recordings of Service Observations

Security classification:  None

System locationThe following locations will each have the equipment that enables service observers to use the vendor’s telephone system to select and record agent calls:  National 800 Number Network (N8NN) sites, regional Office of Quality Performance (OQP) sites, Office of Operations regional offices’ N8NN directors and staff.  Contact the system manager at the address below for the address of these sites.  Records are also located in the central offices of OQP and the Office of Telephone Services.  The address of these offices is Social Security Administration (SSA), 6401 Security Boulevard, Baltimore, MD 21235.

Categories of individuals covered by the system:   All N8NN calls are subject to unannounced service observation.  Recorded telephone conversations between public callers and SSA agents will be stored in the system of records.  Service observers will document the evaluation and enter this data into the system of records.  The system of records will accumulate data from the inputs of evaluations.

Categories of records in the system:  Recorded calls between callers and SSA agents will be maintained in this system of records and will include date and time of the recorded call, the observer’s name, the agent’s unit or module number (not individual agent identifier) and caller’s name (and address, if available). 

Authority for maintenance of the system:  Sections 205(a) and 702(a)(5) of the Social Security Act (42 U.S.C. §§ 405(a) and 902(a)(5)).  The authority to conduct consensual service observation activities, cited in regulation 20 C.F.R. Part 422, Listening-In to or Recording Telephone Conversations, must be renewed every 5 years.  It was renewed on

December 1, 2005. 

Purpose(s):   Electronic recordings of service observations or results will be used for performance assessments, conduct issues, and disciplinary actions.  These recordings will also determine individual employee, unit, and office-wide training needs, as well as the quality of responses, trends, public reactions to policies, legislation, and other public announcements.  The recordings will be used to train service observers to ensure uniform and consistent evaluation criteria and as documentation for any disciplinary and performance-based actions.

Service observers will routinely record calls and access recordings of telephone conversations in the system of records.  Service observers and possibly other site management will use recorded service observed call conversations for determining training needs, ensuring uniform and consistent evaluations, and improving the overall monitoring quality and performance management process.  The manager uses the evaluations to assess agent response quality as well as support any conduct issues and disciplinary actions.  OQP Headquarters and regional personnel will routinely record all calls for a particular site to evaluate a site’s quality.  OTS and regional N8NN director staffs will also use the system of records to evaluate the management of the service observation program, and the overall quality, integrity, and courtesy of agent responses.  Moreover, they will be able to view the details about the calls observed, the reasons callers called the N8NN, the programs involved, and the types of errors for assessing training needs on a regional or national basis.

Routine uses of records maintained in the systems of records, including categories of users and the purposes of such use:  Routine uses disclosures are as indicated below:

1.   To the Office of the President for the purpose of responding to an individual pursuant to

     an inquiry received from that individual or from a third party on his/her behalf.

2.   To a congressional office in response to an inquiry from that office made at the request of the subject of a record.

3.   To the Department of Justice (DOJ), a court or other tribunal, or another party before such tribunal when:

a.  SSA or any component thereof; or

b.  any SSA employee in his/her official capacity; or

c.  any SSA employee in his/her individual capacity when DOJ (or SSA when it is   

           authorized to do so) has agreed to represent the employee; or

d.  the United States or any agency thereof when SSA determines that the litigation is    

     likely  to affect the operations of SSA or any of its components,

is a party to litigation or has an interest in such litigation, and SSA determines that the use of such records by DOJ, a court or other tribunal, or another party before such tribunal, is relevant and necessary to the litigation, provided, however, that in each case, SSA determines that such disclosure is compatible with the purpose for which the records were collected.

4.      To SSA contractors and other Federal agencies, disclosure may be unrestricted as necessary, for assisting SSA in the efficient administration of its programs.  We will disclose information under this routine use only in situations in which SSA may enter into a contractual or similar agreement with a third party to assist in accomplishing an agency function relating to this system of records.

5.      To student volunteers, individuals working under a personal services contract, and other workers who technically do not have the status of Federal employees, when they are performing work for SSA as authorized by law, and they need access to personally identifiable information in SSA records in order to perform their assigned Agency functions. 

6.      To Federal, State, and local law enforcement agencies and private security contractors as appropriate, information necessary:

a)    to enable them to protect the safety of SSA employees and the public, the security of the SSA workplace, and the operation of SSA facilities; or

b)   to assist investigations or prosecutions with respect to activities that affects such

safety and security or activities that disrupt the operation of SSA facilities.

7.      To the General Services Administration and the National Archives Records Administration (NARA) under 44 U.S.C. § 2904 and § 2906, as amended by the NARA Act of 1984, information which is not restricted from disclosure by Federal law for the use by those agencies in conducting records management studies. 

8.      To the Equal Employment Opportunity Commission when requested in connection with investigations into alleged or possible discriminatory practices in the Federal sector, examination of Federal affirmative employment programs, compliance by Federal agencies with the Uniform Guidelines on Employee Selection Procedures, or other functions vested in the Commission.

9.      To the Merit Systems Protection Board or the Office of Special Counsel in connection with appeals, special studies of the civil service and other merit systems, review of rules and regulations, investigation of alleged or possible prohibited personnel practices, and other such functions promulgated in 5 U.S.C. Chapter 12, or as may be authorized by law. 

10.  To the Federal Labor Relations Authority, the Office of the Special Counsel, the Federal Mediation and Conciliation Service, the Federal Service Impasses Panel, or an arbitrator requesting information in connection with the investigations of allegations of unfair practices, matters before an arbitrator or the Federal Service Impasses Panel.

11.  To the Department of Justice for:

a)      investigating and prosecuting violations of the Social Security Act to which criminal  

     penalties attach;

b)      representing the Commissioner; or

c)      investigating issues of fraud or violation of civil rights by agency officers or employees.

12.  To appropriate Federal, State, and local agencies, entities, and persons when (1) we suspect or confirm that the security or confidentiality of information in this system of records has been compromised; (2) we determine that as a result of the suspected or confirmed compromise there is a risk of harm to economic or property interests, identity theft or fraud, or harm to the security or integrity of this system or other systems or programs of SSA that rely upon the compromised information; and (3) we determine that disclosing the information to such agencies, entities, and persons is necessary to assist in  our efforts to respond to the suspected or confirmed compromise and prevent, minimize, or remedy such harm.  SSA will use this routine use to respond only to those incidents involving an unintentional release of its records.

Policies and practices for storing, retrieving, accessing, retaining and disposing of records in the system of records:

Storage:   The records created from the Recordings of Service Observations system of records are electronic only.

Retrievability:  The observers, management, OQP, and regional and Headquarters staffs authorized to conduct service observations will have access to the recordings.  Recorded call data will be stored and retrieved by a combination of day, date, time of the call, the type of call, and the observer’s name and the agent’s unit number. 

Safeguards:  Information is compartmentalized so that service observers who have an official need for the information in the performance of their duties at one site have access only to data or records at their sites, and that those authorized outside the site may only access site information within their jurisdictions.  Regional office 800 number director staffs will have access to all sites in their respective regions.  OQP and Headquarters observers will have nationwide access.  Access is through a PIN-based authorization process.

Established safeguards for automated records are in accordance with the Systems Security Handbook.  For computerized records electronically transmitted between SSA’s central office and field office locations (including organizations administering SSA programs under contractual agreements), safeguards include a lock/unlock password system, exclusive use of leased telephone lines, a terminal-oriented transaction matrix, and an audit trail.  Access for additional information regarding the safeguards SSA employs to protect its paper and automated records.

Retention and disposal:  When the service observer listens to a call, an automated Service Observation Report form is completed.  Both the observer or manager and the agent sign the form.  Per the current personnel file retention procedures, we will maintain paper copies of the Service Observation Report Form in the SF-7b extension personnel files.  The system of records maintains recorded call conversations for 14 days, at which time the call conversations are automatically destroyed.  If the employee’s recorded service observation results in an unsatisfactory evaluation by the service observer, however, the call conversation is automatically retained for 60 days from the date of the call and then destroyed.  The manager will archive the recording for a full two-year period from the date all actions are closed if the evaluation results in a performance or conduct issue, the recording is used to support a disciplinary action, the employee files a grievance, or if the employee files an Equal Employment Opportunity complaint.  In these situations, the employee may request to listen to the recorded call, and management will then make the recording available for listening within five business days of the request, whenever possible.  Management must be present while the employee listens to a recorded call.  The employee receives a copy of the sanitized Service Observation Report Form, and the manager places the original sanitized form in the SF-7b extension file.  When an EEO complaint is involved, the manager will download the recording to a disk and place the disk in the employee’s SF-7b extension personnel file for the four-year retention period, or as long as is required for the duration of pending/ongoing litigation. 

Only members of management may delete records from the system of records.  If the agent conversation involves litigation, management will archive the recording in the system of records. 

The Agency established a retention and disposal schedule for the retained recordings.  Current policies set for retention and destruction of personnel records cover forms placed in the SF-7b extension file.

System of records manager(s) and address(es): 

Associate Commissioner for Telephone Services

Office of the Deputy Commissioner for Operations,

Office of Telephone Services

6401 Security Boulevard, 4840 Annex Building

Baltimore, Maryland 21235

Notification procedure(s):   An individual can determine if this system of records contains a record about him/her by writing to the system of records manager(s) at the above address and providing his/her name, work telephone number, or other information that may be in the system of records that will identify him/her.  An individual requesting notification of records in person should provide the same information, as well as provide an identity document, preferably with a photograph, such as a driver’s license or some other means of identification.  If an individual does not have any identification documents sufficient to establish his/her identity, the individual must certify in writing that he/she is the person claimed to be and that he/she understands that the knowing and willful request for, or acquisition of, a record pertaining to another individual under false pretenses is a criminal offense.

If notification is requested by telephone, an individual must verify his/her identity by providing identifying information that parallels information in the record to which notification is being requested.  If it is determined, that the identifying information provided by telephone is insufficient, the individual will be required to submit a request in writing or in person.  If an individual is requesting information by telephone on behalf of another individual, the subject individual must be connected with SSA and the requesting individual in the same phone call.  SSA will establish the subject individual’s identity (his/her name, SSN, address, date of birth and place of birth along with one other piece of  information such as mother’s maiden name) and ask for his/her consent in providing information to the requesting individual.  Authentication will be conducted before connecting with both parties.

If a request for notification is submitted by mail, an individual must include a notarized statement to SSA to verify his/her identity or must certify in the request that he/she is the person claimed to be.  Moreover, that he/she understands that the knowing and willful request for, or acquisition of, a record pertaining to another individual under false pretenses is a criminal offense.  These procedures are in accordance with SSA Regulations (20 C.F.R. § 401.40(c)).

Record access procedures:  Same as Notification procedures.  Requesters should also reasonably specify the record contents being sought.  These procedures are in accordance with SSA Regulations (20 C.F.R. § 401.40(c)).

Contesting record procedures:  Same as Notification procedures.  In addition, requesters should reasonably identify the record, specify the information they are contesting, and state the corrective action sought, and the reasons for the correction, with supporting justification showing how the record is incomplete, untimely, inaccurate or irrelevant.  These procedures are in accordance with SSA Regulations (20 C.F.R. § 401.65(a)).

Record source categories:   The source of electronic/paper records retained at sites is the software recording system provided by a vendor providing telecommunications services.  

System of records exempted from certain provisions of the Privacy Act:  None.