Change in Social Security Disclosure Rules

One valuable genealogical resource has been U.S. Applications for Social Security, Form SS-5. Through the Freedom of Information Act (FOI) researchers can request a photocopy of the form, which includes a lot of valuable information about the deceased, by submitting a Form SS-711. The fee for this service depends on whether or not you can supply a Social Security Number for the deceased. Usually, the Social Security Number is found from the Social Security Death Index (SSDI). Several online sources have the SSDI including FamilySearch.org's Historical Record Collections.

I say that this resource "has been" valuable, because according to a blog post by Megan Smolenyak which includes a copy of a letter from the Social Security Administration's Daniel F. Callahan, Acting Executive Director of the Office of Privacy and Disclosure, which states, "Under our current policy, we do not release the parents' names unless they are proven deceased or the number holder on the SS-5 is at least 100 years of age." One of the main reasons for paying the rather high fee for a photocopy of the SS-5 was to learn the names of the deceased's parents. Apparently, from Megan's comments this change in policy occurred without any particular notice. I have been unable to find a reference to the policy anywhere. Unfortunately, there is no reference to any ruling, administrative decision or other action implementing the policy.

There is an appeal process through the Federal Courts and by making an appeal to the Office of Government Information Services, National Archives and Records Administration. I think as a minimum the Social Security Administration should have referenced the source for its change in policy.

Any one interested in challenging the ruling or whatever it is? I have been trying to imagine what interest of living parents is being protected. A person born in 1940 would be about 71 (simple math) today. If the person's mother was 17 at the time of his birth, she would be 88 years old today. If you can prove the parents to be deceased, then you don't need the SS-5, right?

Megan is researching younger people, apparently veterans killed in action. Researching people who lived most of their lives after 1930 has always been difficult. I know of a lot of other sources, although much more expensive than the SS-5 duplication, that can give a lot of information about more recent people, but it is still puzzling as to why the SSA thinks there is some privacy interest to be protected.