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Defense Privacy Board Advisory Opinions
DISCLOSURE OF RECORDS CONCERNING CHARITABLE CONTRIBUTIONS OR PARTICIPATION IN SAVINGS BOND PROGRAMS
Disclosure of information contained in systems of records concerning employees' or service members' participation in charitable or savings bond campaigns may be necessary to those officers and employees of the Department of Defense components maintaining the systems of records who have a need for the information in the performance of their duties. 5 U.S.C. § 552a(b)(1). Disclosure under subsection (b)(1) is based on a "need–to–know" concept; consequently, disclosure would be authorized to those personnel requiring the information to discharge their duties, such as payroll and allotment clerks, key persons, and campaign aides who assist directly in implementation of the campaign. Disclosure to supervisors is neither related directly to any campaign requirement nor consistent with disclosure provisions of the Privacy Act. Disclosure should be restricted to personnel with a direct functional relationship to a campaign and for campaign purposes only. Personnel authorized to receive this information should be briefed on their responsibilities under the Privacy Act and warned against unauthorized disclosure.