Social Security Number Policy

Policies and Procedures Manual Section 21

Introduction to Social Security Number Privacy Act

The Michigan Social Security Number Privacy Act (MCL §445.81 et seq.) requires that universities institute a policy that protects the privacy of Social Security numbers. Western Michigan University recognizes the importance and sensitivity of an individual's private and personal information, including an individual's Social Security number. The University, in its capacity as an employer and an educational institution, collects a variety of personal and private information, including Social Security numbers. The University strives to ensure the proper handling of all private, personal information, including compliance with all legal requirements regarding such information.

Western Michigan University policy

It is the policy of Western Michigan University to ensure to the greatest extent practicable the confidentiality of Social Security numbers. Social Security numbers are private, personal information that should be utilized only in accordance with University policy on Social Security numbers.

This policy does not alter existing policies regarding the use of Social Security numbers that are more restrictive than this policy. The internal use of Social Security numbers for legitimate university business is not prohibited by this policy. Such internal use must be in compliance with other university policies.

Documents that are no longer needed that contain Social Security numbers must be shredded. Under no circumstances should any document with all or any portion of a Social Security number be disposed of without first being shredded.

Access to and restrictions about Social Security numbers

Access to Social Security numbers is limited to those individuals whose work duties require them to have access to those numbers.

With regard to employees, students, and for other individuals for whom the university must collect Social Security numbers, the following requests for, displays of, or uses of Social Security numbers are prohibited:

1. First, and with regard to students, it is important to note that student grades may not be displayed using all or any portion of a student's Social Security number.
2. Publicly displaying all or any portion of a person's Social Security number;
3. Using all or any portion of a person's Social Security number as an account number unless the Social Security number was used as an account number before January 1, 2006;
4. Using all or any portion of a person's Social Security number on a badge or card;
5. Requiring a person to submit more than 4 sequential digits of her/his Social Security number over an internet connection unless the connection is secure or the transmission is encrypted;
6. Requiring a person to submit more than 4 sequential digits of his/her Social Security number to gain access to an internet website or computer system or network unless the connection is secure, the transmission is encrypted, or a password or other unique personal identification number or other authentication device is also required to gain access to the internet site or computer system or network;
7. Including more than 4 sequential digits of a person's Social Security number in any document mailed to any individual unless:
   
   1. Applicable law requires, permits, or authorizes that the Social Security number appear in the document;
   2. The document is sent as part of an application or enrollment process initiated by the individual;
   3. The document is sent to establish or confirm the status of, service, amend, or terminate an account, contract, policy, or employee or health insurance benefit, or to confirm the accuracy of a Social Security number of an individual who has an account, contract, policy, or employee or health insurance benefit;
   4. The document is mailed:
      
      1. In compliance with the Michigan Freedom of Information Act;
      2. The document is part of a vital record recorded as provided for by law and is mailed to a person entitled to receive the record;
   5. The document or information is mailed by or at the request of an individual whose Social Security number appears in the document or his or her parent or legal guardian.
   6. The document is mailed in compliance with the Health Insurance Portability and Accountability Act (HIPAA) or the Gramm-Leach-Bliley Act.

Permitted uses of Social Security numbers

The use of Social Security numbers to conduct academic administrative activities in the University is discouraged. However, circumstances exist where the use of Social Security numbers is required, particularly in the administration of financial aid and student employment. The University may still use Social Security numbers to conducts its legitimate, internal academic and student employment operations, including generating reports, verifying the identity of students when such identity is in legitimate doubt, and communicating within or between University offices. Social Security numbers used for these purposes should be treated as confidential and the privacy and integrity of numbers should be preserved to the greatest extent practicable.

Circumstances in which the use of a person's Social Security number are allowed:

1. If the use is pursuant to court order, state or federal law, or in legal discovery, or
2. If the use is for the purpose of law enforcement or prosecution.
3. The administrative use of Social Security numbers in the normal course of business is allowed:
   
   • To verify the identity of an individual or to do some other similar administrative purpose related to an account, transaction, product, service, or employment or proposed account, transaction, product, service, or employment.
   • To investigate an individual's claim, credit, criminal, or driving history;
   • To detect, prevent, or deter identity theft or another crime;
   • To lawfully pursue a legal right;
   • To provide or administer employee health insurance or membership benefits, claims, or retirement programs.

Violations

A violation of this policy constitutes grounds for discipline up to and including discharge under the human resources policy and procedure manual or applicable collective bargaining agreement. In addition, a knowing violation of this policy may also constitute a violation of the Michigan Social Security Number Privacy Act and subject the person to criminal prosecution under Michigan law.

Questions

Any questions regarding this policy should be directed to an employee's supervisor.

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