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The National

Security numbers, any use of a driver's license

statement on the new Form 1583 informing

by a box renter would mean revealing that

CMRA box holders that information may be

Coalition Against

individual's Social Security number.

made available to the public.

Domestic

The privacy rules state that

That situation became even more confus-

Violence stated

ing on June 25, 1999, when, in response to

(b)(1) The Postal Service will not dis-

public pressure and a letter of concern from

that "these

seminate information about an indi-

several members of Congress, Postal Service

unnecessary regu-

vidual . . . unless:

authorities announced that "a notice for

(i) The individual to whom the

public comment will be published in the

lations make it

record pertains has requested in writ-

Federal Register regarding the proposed

more difficult for

ing that the information be dissemi-

update policy which will prohibit release,

a battered

nated, or

except for law enforcement purposes, of

(ii) It has obtained the prior written

address information."14 So now there could

woman to effec-

consent of the individual to whom

be two USPS postings in the Federal Register

tively use a com-

the record pertains.12

for public comment, one to allow release of

information and one to restrict release. That

mercial postal

confusion suggests just what a poor job the

As noted earlier, private box holders are

box to keep her

Postal Service will do in its implementation

asked on Form 1583 if they plan to use the

location confi-

of those regulations and argues for their

boxes for doing business with the "public."

repeal.

The Postal Service has informed CMRA oper-

dential."

The release of personal information is one

ators that "information required to complete

of the most serious problems with the new

this form may be available to the public if

private box regulations. Business box holders

`Yes' in block 5, Form 1583 is checked."

could find their personal information

Although there is some ambiguity about

acquired by "identity thieves," criminals who

which organization, the CMRA or the Postal

use such data to obtain credit card numbers

Service, will furnish such information to the

and other personal facts that would allow

public, it is clear that personal information

them to charge bills to others or steal from

about box holders will be publicly available.

bank accounts. In such cases, what are the lia-

Such a practice violates the Postal Ser-

bility exposures of the Postal Service and the

vice's own privacy regulations. On June 9,

CMRA operator? The new regulations do not

1999, in the Federal Register, the USPS posted

address those problems.

its intention to change Title 39, U.S. Code,

In some instances, access to confidential

Part 265, the prohibition "against disclosure

information could be tragic. For example,

of information in PS Form 1583." The Federal

women who use private boxes for business

Register entry reads:

purposes might find stalkers or other danger-

ous people acquiring home addresses courtesy

Under the rule change, the recorded

of the new regulations. On June 15, 1999, The

business name, address, and tele-

National Coalition Against Domestic Vio-

phone number of the addressee

lence, a group that helps women who face

using a . . . CMRA private mail box

such threats, issued an "Action Alert" on those

. . . for purposes of soliciting busi-

postal regulations. It stated that "the impact

ness with the public will be fur-

for domestic violence victims is potentially

nished to any person upon request

fatal." The alert added that "these unnecessary

without charge.13

regulations make it more difficult for a bat-

tered woman to effectively use a commercial

The Postal Service seems to acknowledge

postal box to keep her location confidential."

that it has no authority to release such pri-

The new CMRA regulations also state that

vate information. Thus, the proposed rule

"a parent or guardian may receive delivery of

change raises a question of the legality of the

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