Access, Use and Retention of Social Security Numbers (AP-01-106)

UW-River Falls Administrative Policy
Policy ID: AP-01-106
Effective: September 19, 2006
Revision: September 2011
Review: 3 years

Access, Use and Retention of Social Security Numbers

Maintained by: ACBF
Approved by: Chancellor
Next Review Date: September 2014


Printable PDF versiondocument

Policy

The Privacy Act of 1974 established a set of criteria that must be met in order to solicit a person’s Social Security Number. Additionally, Federal laws such as the Family Educational Rights and Privacy Act (FERPA) place restrictions upon the use and access to private information which Social Security Numbers are considered to be. Finally, retention and storage of items containing Social Security Numbers must also be considered to avoid inappropriate access or the retention of private information beyond the period for which it is legally required.

Generally, faculty, staff and students can be identified by means other than their Social Security Number (e.g. Falcon Account Number). Therefore, the rationale for soliciting a Social Security Number will need to be compelling or the request for such a solicitation will be disallowed.

Authority

The UW-River Falls Chancellor issues this policy in accordance with the Administrative Policy process.
The ACBF is responsible for the administration of this policy. Request an exception to this policy by writing to administrative-policy@uwrf.edumail.

Sanctions and Appeals Process

Failure to adhere to the provisions of this policy may result in appropriate disciplinary action as provided under existing procedures applicable to students, faculty, and staff, and/or civil or criminal prosecution.

Procedure

The Assistant Chancellor for Business and Finance shall review and approve or reject all requests to solicit Social Security Numbers.

University Responsibilities

  1. To collect and use Social Security Numbers only as permitted or required by Federal or State law, and only as reasonably necessary for the proper administration or accomplishment of the university’s business, government and educational purposes.
  2. To provide notice as required by Section 7(b) of the Privacy Act of 1974 whenever the disclosure of a Social Security Number is requested.
  3. To limit access to and display of Social Security Numbers to only those individuals with a valid job-related need to know. Electronic access to Social Security Numbers within UWRF systems will be reviewed at least every two years.
  4. To promptly and securely destroy records and other items containing Social Security Numbers once the legally required time period for retaining such records or items has elapsed. Items or records of historical significance may be excluded from this requirement upon the approval of the Vice Chancellor for Administration & Finance.

Department/Unit Responsibilities

  1. Departments and units will review and modify all existing and newly created forms or other objects that solicit Social Security Numbers to ensure that those items comply with the Privacy Act of 1974. The document “Guidelines for Soliciting Social Security Numbers” (attached) should be followed to ensure compliance. Any form or object that solicits a Social Security Number must be submitted for approval using the “Request for Approval to Solicit or Grant Access to Social Security Numbers” (attached) form. Electronic access to Social Security Numbers stored within University systems must also be requested using this form.
  2. The department or unit administrators must ensure that only persons with a valid job-related need to know have access to Social Security Number information that is solicited or retained by the department or unit.
  3. Departments and units should review any stored or retained records or objects that contain Social Security Numbers and, in consultation with the University Archivist, should ensure that said records or objects are properly and securely destroyed in a timely manner at the termination of their legally required retention period or transferred to the University Archives for permanent confidential/restricted storage.

Related Documents 

  1. Privacy Act of 1974. http://www.justice.gov/opcl/privstat.htmlink
  2. Family Educational Rights and Privacy Act (FERPA). http://www2.ed.gov/policy/gen/guid/fpco/pdf/ferparegs.pdfdocumentlink
  3. Memo from the UW System Board of Regents dated October 18, 2005, on the “Safeguarding of Student Social Security Numbers in the UW System.” http://www.wisconsin.edu/audit/safeguardssn.pdfdocumentlink

Contact

Please direct questions about this policy to administrative-policy@uwrf.edumail.