The Postal Service keeps employees’ phone numbers and email addresses in a Privacy Act system of records called General Personnel Records (USPS 100.000). The Privacy Act authorizes disclosure from this system “for routine uses.” Routine uses are defined as disclosures that are compatible with the purpose for which the information was collected, in other words, disclosures that are appropriate and necessary for the efficient conduct of government business.

One routine use for General Personnel Records (USPS 100.000) is #6, “Disclosure to Labor Organizations. As required by applicable law, records may be furnished to a labor organization when needed by that organization to perform its duties as the collective bargaining representative of Postal Service employees in an appropriate bargaining unit.”

An example of a situation when the union may need these records is after an “Act of God” event when large numbers of employees are prevented from reporting to work. Employees are typically denied “Act of God” leave. The steward then asks to interview each employee for a class action grievance. This request is often denied. I asked an NLRB attorney, in this hypothetical situation what recourse do I have? I was told to make a request for information for the employees’ phone numbers and/or email addresses, so I could interview them off-the-clock. They would support that if it was the only way to interview them. I was referred to Nestle Purina Petcare Co. (17-CA-22997; 347 NLRB No. 91).

Disclosures Authorized by the Privacy Act: “The Privacy Act authorizes disclosures in the following twelve circumstances: #3. For routine uses for which the agency has provided proper notice.”

Standard Routine Uses: “The following standard routine uses apply to USPS systems of records. In general, standard routine uses 1. through 9. apply to general systems — systems relating to employees, finance, investigations, litigation, and other systems not primarily related to USPS customers. #6. Disclosure to Labor Organizations. As required by applicable law, records may be furnished to a labor organization when needed by that organization to perform its duties as the collective bargaining representative of Postal Service employees in an appropriate bargaining unit.”

General Personnel Records (USPS 100.000) Categories of Records in the System: Employee, former employee, and family member information: Name(s), Social Security Number(s), Employee Identification Number, date(s) of birth, place(s) of birth, marital status, postal assignment information, work contact information, home address(es) and phone number(s), personal email address, finance number(s), duty location, and pay location….Standard routine uses 1. through 9. apply.” Note that the Postal Service even keeps the email address for retired employees. Sometimes a retiree needs to be contacted for a grievance.

Article 31, Section 2 and the MOU Re Bargaining Information should be updated for the 21st century and include an employee’s phone number and email address. Disclosure of this information to a labor organization is already listed as a “routine use.”