Unit 2: General Issues Where there is a legitimate basis to disclose information to family members without the consent of the individual concerned, UNHCR Offices are advised to limit such information to the minimum necessary.15 In the absence of consent, information regarding an asylum-seeker or refugee should generally be limited to confirmation of the fact that the person has registered or is in contact with UNHCR. Where specific and legitimate purposes to disclose additional information are presented, the request should be referred to the Protection staff member who is designated under established procedures in the UNHCR Office to determine the appropriate scope of disclosure. Where disclosure of information regarding an asylum-seeker or a refugee is not considered in that person’s best interest, the UNHCR Office may also refer the family member to partners conducting family tracing or existing means or mechanisms for family tracing/reunification. 2.1.8 Disclosure of Information on Individual Files within UNHCR The Applicant’s prior consent is not required for sharing personal data and other information on an Applicant’s file within the UNHCR Office, between UNHCR Offices or with Headquarters as far as necessary and legitimate. Such sharing would, for instance, be legitimate for the purposes of determining an Applicant’s refugee status claim, including in cases where an Applicant moves forward to another country and registers with the UNHCR’s Office in that country, where review of a RSD decision by Headquarters is required, or where information gathered through other protection interventions is necessary to inform the scope of the RSD Interview and the interviewing techniques, and to make the necessary accommodations to facilitate an Applicant’s participation in the RSD process. However, access to personal data and other information on an Applicant’s file, whether held in physical or electronic form, should be restricted to authorized UNHCR staff who have a legitimate need to know in order to carry out their functions.16 2.1.9 Procedures for Responding to Individual Requests for Personal Data or Other Information on the RSD File In addition to data sharing arrangements/data transfer agreements (e.g. with implementing partners, host country authorities, etc.), UNHCR Offices should establish procedures for responding to individual requests for information from or about asylum-seekers and refugees. 15 For instance, the information may allow reconnection with the family member rather than reunification (e.g. telephone number, rather than address). 16 For instance, interpreters are not permitted access to individual files of persons of concern. If interpreters have exceptionally been assigned additional tasks, which require access to individual files, such access must be strictly limited to what is necessary to carry out authorized responsibilities, and should be closely supervised (see § 2.5.8 – Access by Interpreters to Individual Files of Applicants). 29