Vice Chancellor for Administration and Finance Home

Administrative Policies

AP 1 State Telephone System and Cellular Telephone Sets

AP 2 Telecommunications Equipment (Voice)

AP 3 Smoking

AP 4 Safety and Health

AP 5 Risk Management Policy

AP 6 Parking Regulations

AP 7 Sign Posting Policy

AP 8 Chargeback of Physical Plant Services

AP 10 Building Keys

AP 11 Fleet Vehicles

AP 12 Records Hold Policy

AP 13 Dispensing of Hearing Aids

AP 14 Policy on Business Activities

AP 15 Dangerous Weapons on Campus

AP 16 Collection of Indirect (Overhead) Costs

AP 17 Distribution of Indirect (Overhead) Costs

AP 18 Seat Belt Use

AP 19 Use of University Facilities

AP 20 Athletic Camps and Clinics

AP 21 University-Foundation Relationships

AP 22 Employee Accident/Injury Procedures

AP 23 Naming of Rooms and Buildings on Campus

AP 24 Postal Policy

AP 25 Requirement for a Mandatory Residential Dining Plan

AP 26 Requirement for Mandatory Housing

AP 27 Records Management Program

AP 29 Bad Check Policy

AP 30 In-Line Skates and Skateboarding

AP 31 Computer Software Use

AP 32 Inclement Weather Practice

AP 33 International Student Tuition Remission Policy

AP 36 Information Security

AP 37 Conflict of Interest/Financial Disclosure Policy

AP 38 Health Insurance Requirement for International Students

AP 39 Reuse Policy for Replaced Computers

AP 40 Alcohol Beverages on Campus

AP 41 Computer Replacement Policy

AP 42 Outreach Residual Funds

AP 43 Summer Session and J-Term

AP 44 Use of Copyrighted Material

AP 45 Shared Radio Spectrum Management and Coordination

AP 46 Emeriti Status for Unclassified Staff (Faculty/Academic Staff)

AP 47 Honored Retiree Status for Classified Employees

AP 48 Application for Immigrant Visas

AP 49 Determination of Outreach Course

AP 50 Cellular Telephone Policy

AP 52 Access, Use, and Retention of Social Security Numbers

AP 53 Full-time Status with a Reduced Course Load

AP 54 Advertising, Sponsorship, and Promotion of Alcohol and/or Tobacco Products on Campus

AP55 Licensing of UWRF Registered Marks

AP56 Advertising and Sponsorship in University Print and Online Publications

University of Wisconsin-River Falls Administrative Policy Paper
Number: AP 52
Date Issued: September 19, 2006
Subject: Access, Use, and Retention of Social Security Numbers

1.0 POLICY/PURPOSE:

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.

2.0 OVERVIEW/BACKGROUND:

2.1 Privacy Act of 1974.

2.2 Family Educational Rights and Privacy Act (FERPA).

2.3 Memo from the UW System Board of Regents dated October 18, 2005, on the “Safeguarding of Student Social Security Numbers in the UW System.”

3.0 UNIVERSITY RESPONSIBILITIES:

3.1 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.

3.2 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.

3.3 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 UW-RF systems will be reviewed at least every two years.

3.4 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 and Finance.

4.0 DEPARTMENT/UNIT RESPONSIBILITIES:

4.1 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.

4.2 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.

4.3 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.

5.0 PROCEDURE:

• The Vice Chancellor for Administration and Finance shall review and approve or reject all requests to solicit Social Security Numbers.

Guidelines for Soliciting SSN
Effective 09/01/2006, UW-River Falls will be requiring approval for any solicitation of Social Security Numbers. The solicitation of Social Security Numbers by a university department is allowed only when doing so is necessary to fulfill a record-keeping or reporting requirement. Such a requirement is typically made by a federal or state government agency, such as th Internal Revenue Service. Generally, only the following instances are allowable rationale for solicitation:

* When an individual is being employed and taxes are being collected that must be associated with the individual's Social Security Number
* Financial assistance transactions are being made that must be reported using an individual's Social Security Number

The Identification of individuals is no longer a valid rationale for soliciting Social Security Numbers.

Electronic versus Paper-based Solicitations

These guidelines apply to both electronic solicitations and paper-based solicitations of Social Security Numbers. There are, however, some special considerations for each type of solicitation. For electronic solicitations, care must be taken to ensure that the electronic form of the SSN is available for viewing only to those individuals with an approved need to know. Additionally, the storage and transmittal of electronic data containing a SSN must be properly protected by encryption and/or firewall technology.

Paper-based solicitation must also be properly secured so that only those individuals with an approved need to know have access to the SSN information contained on a paper document. Storage and transportation of paper records containing SSN information must be done securely so that inappropriate individuals are not able to view the SSN information contained on the records.

Mandatory versus Voluntary Disclosure of Social Security Number Requirement

Per the Privacy Act of 1974 (as amended), any solicitation of Social Security Numbers must contain a disclosure stating to the person whose SSN is being solicited whether or not it is mandatory for them to provide their SSN to you.

Example: “Federal law allows the UW System to request and use your social security number. While you are not legally required to provide your social security number on this form, you are strongly encouraged to do so. You will be required to provide your social security number when you apply for financial aid or the new educational tax benefits.” — UW Application for Undergraduate Enrollment.

Statutory Authority Under Which Social Security Number is Solicited Requirement

Per the Privacy Act of 1974 (as amended) , any solicitation of Social Security Numbers must contain information about the statutory or other authority under which the SSN is being solicited.

Example: “Federal law (20 U.S.C. 1232g; 34 C.F.R.s.99.1 et seq.) recognizes the student social security number as “personally identifiable information.” Accordingly, this information may only be disclosed under certain circumstances, including the following: to other institutional officials; to representatives of state and local educational authorities; in connection with financial aid; for research; to collection agents in connection with university-related business; pursuant to an order from a court of law; and in other circumstances as required by state or federal law.” — UW Application for Undergraduate Enrollment.

Statement as to Uses of Social Security Number Requirement

Per the Privacy Act of 1974 (as amended) , any solicitation of Social Security Numbers must contain a statement describing the use or uses that the solicitor will make of the SSN.

Example: “If you intend to apply for financial aid, the social security number is required. As applied to financial aid, it may be used for a number of purposes, including verification of identity of the borrower or recipient and as an account number throughout the life of a loan; determination of program eligibility; certification of enrollment and student status; determination of eligibility for deferment, cancellation or repayment by third parties; determination of eligibility for disability or death claims; and, in case of delinquent or defaulted loans, for tracing the borrower and collecting.” — UW Application for Undergraduate Enrollment.

The following form must be completed and approved prior to requesting any Social Security Numbers

Request for Approval to Solicit or Grant Access to Social Security Numbers

 

 

 

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