EPIC Urges HHS to Abandon Database Changes that Violate Privacy of TANF Recipients 

EPIC Urges HHS to Abandon Database Changes that Violate Privacy of TANF Recipients 

Today, EPIC submitted comments to the U.S. Department of Health and Human Services’ Administration for Children and Families (ACF) urging the ACF to retract its recent System of Records Notice (SORN) for the Temporary Assistance for Needy Families (TANF) system of records and abandon its new proposals to expand the purpose and scope of that system.  

The proposed changes would greatly expand the information held by the ACF, granting the agency broad authority to collect, process, and redisclose sensitive personal information about current and former recipients of TANF assistance and members of their households that the ACF previously could not access. This information would include, among other things, Social Security Numbers and citizenship/immigration status.  

In comments to the ACF, EPIC argues that these proposals should be quickly abandoned. Particularly, EPIC argued that the ACF’s Notice was too vague for anyone to evaluate and contained a new routine use for TANF data that was concerningly overbroad and allowed disclosure of personal information with little guardrails. Further, EPIC argues that the ACF does not have legal authority to amass and disclose TANF data, meaning the agency’s proposal would violate multiple statutes, including the Privacy Act of 1974, the Social Security Act, and the very law that created TANF. Finally, the ACF’s proposal to compare the personal information of TANF recipients against other databases violates the Computer Matching and Privacy Protection Act because the agency has no publicly available computer matching agreements.  

EPIC routinely comments on federal agencies’ collection and use of personal information, including the systems and databases used in the provision of public benefits like TANF.