This All County Letter serves to remind counties and users of the California Integrated Vital Records System (Cal-IVRS) on the proper handling of documents generated by Cal-IVRS. The birth or death certification pages, review copies, and working copies of the birth or death certificate generated by Cal-IVRS are solely for use in the preparation and registration of the birth or death record. Per guidance provided during training, all Cal-IVRS users are to confidentially destroy these documents as soon as they submit the record to the local registrar, if not sooner.

Printing or distributing working copies of these birth or death record documents for any purpose other than preparing the record violates state law and constitutes unacceptable use of the system and disclosure of the system's data. This includes distributing copies to either of the parents or decedent’s family/informant. Birth and fetal death records contain both the public and the confidential portion of the certificate. Distributing copies of the birth records is a violation of Health and Safety Code (HSC) Section 102430, which states in part, "The birth hospital shall not further disclose the information nor use the information for purposes other than allowed by this part." Additionally, distributing copies of the fetal death records is a violation of HSC Section 103025 which states in part, “information included in the second section shall be kept confidential pursuant to Section 102430.”

Further, HSC Section 103525 (b) states, "Notwithstanding subdivision (a) or any other law, the State Registrar, local registrar, or county recorder shall provide certified copies of birth, death, and marriage records only as authorized under Section 103526 or 103526.5." This designates that regardless of any other laws, including the Public Records Act, copies of vital records (or portions thereof) may only be issued if the requirements of HSC Sections 103526 and 103526.5 are met, which includes receipt of proper application and fee and requires the copy be issued in a "certified" format in compliance with the security features designated.

Releasing any of these documents in any form or allowing the documents to be photographed or copied in any manner is also a violation of the Cal-lVRS  Participant Agreement signed by medical facilities, funeral establishments, coroners, medical examiners, and local health districts. Section VI of the Cal-lVRS Participant Agreement states, "The Participant, and its workforce members and agents, shall not disclose any Cal-lVRS Data for any purpose other than carrying out the Participant's obligations under the statutes and regulations set forth in Attachment A, or as otherwise allowed or required by state or federal law."

The Cal-lVRS Participant Agreement remains in effect for five years after the latest signature date. However, if one or both parties wish to terminate the agreement prematurely, they may do so upon 30 days' advance notice. CDPH may also immediately terminate the agreement upon breach of any provision of the agreement. At its sole discretion, CDPH may give the participant 30 days to remedy the breach.

Misuse of Cal-IVRS accounts in violation of the Cal-IVRS Participant Agreement may result in user account access restrictions and/or termination of the agreement and access to Cal-IVRS. Without access to Cal-IVRS, a medical facility, coroner, medical examiner, or funeral establishment would be required to prepare paper birth or death records and submit the hard copy records to the local registrar, or a local health district would be required to register hard copy records and submit them to the State Registrar.

In the event CDPH is made aware of an incident as described above, the Cal-IVRS Help Desks will notify the CDPH Office of Legal Services to determine if the incident constitutes a breach of the signed agreement. Additional action may be necessary depending on the outcome of this determination.

CDPH requests all medical facilities, funeral establishments, coroners, medical examiners, and local health districts to address document security, along with the other terms of the Participant Agreement, with all of their Cal-IVRS users, and implement appropriate safeguards as required in Section VIII of the Cal-lVRS Participant Agreement.

If there are any questions regarding this information, please contact the CDPH-VR Birth and Marriage Registration Section at (916) 445-8494 or EBRSHelp@cdph.ca.gov or the Death Registration Section at (916)552-8123 or EDRSHelp@cdph.ca.gov​.

Sincerely,

Original signed by:

Dana E. Moore, MPH, CPH

State Registrar

Deputy Director

Chief Data Officer

Center for Health Statistics and Informatics

California Department of Public Health

​CDPH Vital Records, MS 5103 ●  P.O. Box 997410  ●​  Sacramento, CA 95899-7410

(916) 552-8116  ●   (916) 552-8170 FAX

Internet Address: www.cdph.ca.gov​