The University SSN Policy states: "II.2.All University forms and documents that collect Social Security numbers will use the language included below. It is understood that this language will be implemented on an ‘as reprinted' basis for existing paperwork, with a full compliance date of fall 2002." The "language below" refers to disclosure statements required by federal law. The following information is provided to insure that units and University employees that solicit SSNs are meeting Federal requirements when doing so.
The Privacy Act of 1974 requires that whenever a Social Security number is requested the electronic or physical form used to collect the number must be clearly marked as to whether this request is voluntary or mandatory. When requesting the SSN, you need to:
- explain whether submission is mandatory or voluntary;
- by what authority the number is solicited; and
- what uses will be made of it.
Taken together, these three items constitute an SSN disclosure statement. Please note that all SSN disclosure statements are subject to the approval of the Social Security number Oversight Committee.
How do you know if you need a disclosure statement?
If you answer yes to any of the following questions you must have an SSN disclosure statement:
Do you solicit an individual´s SSN on a printed form?
Do you solicit an individual´s SSN on an online form or application?
Do you request an individual´s SSN at a point of service (e.g., help desk, register, teller)?
Does the disclosure statement have to appear on the form (or computer screen)? I´ve got 10,000 printed forms I´d rather not reprint.
It is acceptable to print the disclosure statement on a separate piece of paper and include it with the form, until the existing stock of forms is exhausted. If the form is also accompanied by a separate set of instructions, it is acceptable to include the disclosure statement in the instruction booklet and reference it by page number on the form (as in the example from the UIUC application below). However, it is preferable to mark whether the submission of the SSN is mandatory or voluntary directly on the form.
ssnapp2
Electronic screens should always include on the display whether the submission of the SSN is voluntary or mandatory. It is acceptable to provide a hyperlink or similar contrivance to the full disclosure statement.
We ask students for their SSN when they walk into our office so we can help them (in order to find their records in a computer system) - do we need a disclosure statement and how do we distribute it?
Yes - and if you explain verbally when you ask for the SSN why you are asking, the vast majority of students will gladly provide it. However having a small stack of printed disclosure statements available to hand to students (or displayed on a wall) will prevent you from having to recite the same information over and over. It is advisable to have an alternate lookup mechanism in place for students that refuse to provide an SSN. The i-card office can provide access to a web based interface to an individual´s demographic information (e.g., name, SSN, digital photo) keyed on their UIN (also known as their i-card number). This permits you to request the UIN in place of the SSN and still provide the usual service.
Okay, so how do I create or get a hold of an approved disclosure statement?
- Please collect the following information:
Department/Unit name
How is the SSN utilized in your department?
Is the SSN required or voluntary?
If required, by what law, statute, act?
Whose SSN do you collect (i.e. students, employees, etc.)?
Who is allowed access to this information?
What happens if someone refuses to provide his/her SSN?
Could anything else (i.e. the University Identification Number) substitute for the SSN?
- If you would like to create your own disclosure statement, use the collected information and the following template to create a draft disclosure statement. You may want to browse the samples provided to help guide you.
Template
The (dept / unit) requires your Social Security number for the purpose(s) of (fill in the purpose). We are required by (fill in the statute/law) to provide (fill in type of information, i.e. income) reports to (fill in organization). If you do not provide us your Social Security number, then (fill in the consequence). The University will not disclose Social Security numbers without the consent of the individual to anyone outside the University except as mandated by law.
- Email the collected information (and draft statement if you created your own) to the SSN Coordinator for your campus.
Examples of Disclosure Statements