Social Security Number Privacy

To establish a privacy policy concerning the confidentiality of individual social security numbers.

All faculty, staff and students.

Northern Michigan University’s policy is to protect the confidentiality of social security numbers in accordance with the requirements of the Michigan Social Security Number Privacy Act.  Violation of this policy may result in disciplinary action, up to and including dismissal for employees and up to expulsion for students. Individuals who violate the act may also be subject to the civil and criminal penalties provided for in the Act.  

REFERENCES

The Michigan Social Security Number Privacy Act, Public Act 454 of 2004, MCL44.81-.87.

Procedure Description

1.      Northern Michigan University will comply with Michigan State law on protecting the confidentiality of social security numbers.  Therefore, individual social security numbers may only be used as follows:

a.      Use Authorized or Required by Law.  Northern Michigan University may use social security numbers if authorized or required by state or federal statute, rule, or regulation, or by court order or rule, or in litigation.

b.      Administrative Use in the Ordinary Course of Business.  Northern Michigan University may use social security numbers:

·  to verify an individual’s identity, identify an individual, or do another similar administrative purposes related to employment, or proposed employment;

·  to verify an individual’s identity, identify an individual, or do another similar administrative purpose related to an account, transaction, product, service, or proposed account, transaction, product, service;

·  to investigate an individual’s claim, credit, criminal or driving history;

·  to detect, prevent, or deter identity theft or another crime;

·  to lawfully pursue or enforce legal rights, including, but not limited to, an  audit, collection, investigation, or transfer of an employee benefit, claim, debt, receivable, or account or interest in a receivable or account;

·  to provide or administer employee or health insurance or membership benefits, claims, or retirement programs or to administer the ownership of shares of stock or other investments.

2.      Northern Michigan University will comply with the following restrictions on the uses and disclosures of social security numbers:

a.      Public Displays.  Northern Michigan University will not publicly or visibly display all or more than 4 sequential digits of a social security number on University property or on any University identification badge or similar item.

b.      Computer Use.  Northern Michigan University will not require employees to use or transmit all or more than 4 sequential digits of their social security numbers over the internet or on a computer system or network unless the connection is secure or the transmission is encrypted.  Similarly, the University will not require employees to use or transmit all or more than 4 sequential digits of their social security numbers to gain access to the internet or a computer system unless the connection is secure, the transmission is encrypted, or a password or other unique personal identification or authentication device is also required.

c.       Mailing of Documents.  Mailing means the use of U.S. mail or other delivery services that do not require the recipient to sign for the package.

Northern Michigan University will not include all or more than 4 sequential digits of social security numbers on the outsides of envelopes or packages, and will not mail documents or information containing all or more than 4 sequential digits of social security numbers if those numbers are visible without manipulation from the outside of the envelope or package.

*  Northern Michigan University will not include all or more than 4 sequential digits of social security numbers in documents or information mailed to individuals for purposes other than those set forth in Section 1(b) unless: (1) the use of social security numbers is permitted or required under state or federal law; (2) the document is sent as part of an application or enrollment process initiated by the individual; (3) the document is sent to confirm the accuracy of an individual’s social security number for an account, transaction, contract, policy or insurance benefit, or to establish, service, amend, confirm the status of, or terminate the account, contract, policy or benefit; (4) the document or information is mailed by or at the request of an individual whose social security number appears in the document or that individual’s parent or legal guardian; or (5) the document or information is mailed in a manner consistent with specific federal regulations. 

d.      Access to Information and Training.  Northern Michigan University limits access to social security numbers to those employees whose job duties require that they use this information in connection with University business.  Documents and electronic files containing social security numbers will be maintained in a confidential manner, and will not be disclosed to persons other than those working in the specified areas.

e.       Disposal of Documents and Data.  Northern Michigan University will properly dispose of documents containing social security numbers by ensuring that all such materials are shredded prior to discard.  Data stored in electronic format will be rendered irretrievable before computers are discarded or destroyed. 

3.      Use of social security numbers by University departments for reasons other than those mentioned in section 1 and 2 above must obtain approval for such use in advance.  All requests for use of social security numbers by departments must be submitted to one of the following approving officials:

*  For use of student social security numbers:  All requests must be forwarded to the Registrar’s Office.

*  For use of faculty and staff social security numbers:  All requests must be forwarded to the Head of Human Resources.

*  For use of social security numbers for other those mentioned above:  All requests must be forwarded to the Vice President for Finance & Administration.

All requests for the use of social security numbers will include the names of the individuals whose social security number will be utilized/listed; the purpose or reason for utilizing such information; how the information will be utilized; and who will have access to such information.  The Registrar or the Head of Human Resources, or their designee, will coordinate with the requesting official to evaluate the request, determine if other options may be appropriate, and render a decision on whether or not the use of social security numbers by the department is authorized.  Copies of all requests for use of social security numbers, along with the decision rendered on the request, will be maintained on file by either the Registrar’s Office, the Human Resources Department, or the Office of the Vice President for Finance & Administration. 

4.      Northern Michigan University is committed in ensuring the confidentiality of all faculty, staff and students social security numbers.  Therefore, any employee or student who has violated the Social Security Number Privacy Act or this policy is subject to disciplinary action up to and including discharge for employees and up to expulsion for students.