Why do we need a policy on Social Security numbers?
Social Security numbers are issued by the Social Security Administration as a means of identifying individuals. The value of being able to uniquely associate an individual with a short number resulted in the wide use of the Social Security number among government agencies and businesses. With this wide spread use of the SSN it became increasingly clear that it was possible to use the Social Security number to obtain a great deal of information about an individual without their permission. Consequently in 1974 the Federal Government passed legislation that explicitly addresses an individual's Social Security number. This law, The Privacy Act of 1974, expressly states the conditions under which one can solicit a SSN, what obligations the solicitor must meet, and protects the individual's right to services even when withholding their SSN.
Does this mean that I don't have to give the University my Social Security number?
That depends. All employees must provide a valid SSN indeed, your employment paperwork won't even begin being processed until you supply your SSN. Students, generally speaking, must also provide a SSN in order to receive a loan or most scholarships. If you or your parents plan to take a tax credit for tuition paid you must provide your SSN. Naturally, any student applying for any form of employment must provide their SSN. If a student chooses to withhold their SSN at enrollment, but at some later time provides it, for example, to obtain a loan or employment, then they increase the risk that a clerical error could ‘disconnect' their earlier records with their newer records. The student, more than the University, benefits from the submission of his or her Social Security number at the earliest possible time.
I just tried to <get an ID, cash a check, request a transcript or any other service> and was asked for my SSN! Why can't I just give them my ID?
If you were asked for your SSN and no disclosure statement was provided, please contact the SSN policy group at firstname.lastname@example.org with details about the incident. Your name will be kept confidential.
So if I don't need a job, or a loan, or a tax credit, or a scholarship, should I withhold my SSN?
No. Presently all of the University's student record systems rely on the Social Security number to track student records. Providing the University with a valid Social Security number is the best way to ensure that your student records are properly maintained. Hence, when a student enrolls, transfers credits, requests transcripts, or has any information sent from other institutions to the University, the primary means for connecting these pieces of information with the correct student is the Social Security number. If an incoming student does not supply his or her SSN, it may take longer to verify that college entrance tests have been submitted or that transcripts sent from other schools have arrived. This could delay or possibly prevent enrollment. During the delay all the available spots may be filled.
Just what will you do with my Social Security number if I give it to you?
Answering this question was one of the main reasons the University created a policy on Social Security numbers. Your SSN will be treated as a confidential piece of information, similar to student or employee records.
What are you doing to ensure that my SSN is safeguarded from accidental disclosure or theft?
The University is taking a multi-pronged approach to this problem. First we are reviewing systems in which the Social Security number is used and asking whether its use can be discontinued. This is part of an overall effort to minimize or eliminate usage of the Social Security number. Second, on each campus an office has been assigned the responsibility of overseeing how SSNs are handled. This means that there now exists responsible parties whose job it is to make sure SSNs are kept as secure as possible. Finally, documents such as this one are being created as part of a University-wide education program to raise employee awareness of the confidential nature of the SSN. It should also be noted that the policy spells out changes to procedural practices that will enhance SSN security – such as the secure disposal of documents containing SSNs and the encryption of email containing SSNs.
I need Social Security numbers to do my job! Why are you taking these away from me?!
The University will continue to collect and store Social Security numbers. Indeed, we are obligated to do this for the vast majority of the University community. The policy statement expressly acknowledges our right to do so. Furthermore, University employees who in the course of performing their jobs need access to student or employee SSNs will continue to have access to them. Hopefully, as our student and business systems are replaced or enhanced, University Identification Numbers (UIN) will replace our reliance on Social Security numbers to identify individuals.
I'm alway's required to put [faculty/staff/student] SSNs on forms I submit to University Administration. Do I have to continue doing that?
While in many of the cases we've heard of it is not possible to require an individual to provide a SSN, many of our legacy systems do require it. OBFS, HR, and AITS are all in the midst of formally reviewing forms and requests for Social Security numbers and in many instances making the provision of a SSN optional. However in almost every case submitting a form with a SSN when requested will speed the processing of the form and thus enhance service to the faculty, staff, or student in question. Thus where possible you are encouraged, if dealing with faculty, staff, and students, to ask for their UIN and then complete the form with their SSN retrieved from internal departmental sources.
My office doesn't even have a ceiling – how can my unit afford a shredder to ‘securely dispose' of documents with SSNs? (alternatively: We produce 3 billion reports a year – how can I be expected to shred all these?)
Let's address this from two perspectives. First, Social Security numbers are strictly confidential. Whether it's difficult, expensive, or annoying to securely dispose of printed SSNs does not circumvent the University's obligation to treat them as such. Placing printed SSNs in a dumpster is not an acceptably secure disposal mechanism for confidential information.
Second, the policy does not specify a specific means of disposal. Each campus will have to address this issue individually and find a means for safely destroying such documents that is appropriate for the context and magnitude of the problem. What is recommended is that rather than treating the disposal of printed SSNs as a unique and burdensome problem, offices should place it in the context of how they dispose of confidential information in general.
I need to match current data with historical data. How can I do that if the historical data is keyed by SSN and the new data by UIN?
The University has entered a period in which most of our electronic systems/applications have been replaced to not key off of SSNs. Virtually every employee has been confronted with fundamental changes to how they work with student and employee information. With regard to SSNs and historical data, contact your campus SSN office with your specific legacy data needs. Doing so is the only means to ensure that any particular pool of legacy data is addressed.
I heard that <insert your favorite university here> requires SSNs from everyone. Why don't we?
One of the commons sources of confusion surrounding this is the difference between collecting SSNs and requiring SSNs. The University of Michigan, Wisconsin, Minnesota, Indiana, Texas, Oregon, Ohio State, Penn State, Northwestern, North Carolina, and Harvard (for example), will all enroll students who withhold their SSN. All of these schools do attempt to collect SSNs for the same reasons that we will – reporting to various Federal and state agencies, and to expedite record keeping. The Privacy Act of 1974 explicitly states that even for state governments to mandate the submission of the SSN requires a) they had a system of records in place prior to Jan 1st 1975 built on the SSN, and b) there existed a state statue explicitly giving the state the right to the SSN. Students trust the University with their confidential educational record, and it behooves the University to impress upon students that we will protect their Social Security number with the same vigor.