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SSN Policy and Disclosure

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Georgia Southwestern State University

Approved August 23, 2004 by Dr. Michael L. Hanes and the GSW Administrative Council

Social Security Number Policy

I. Purpose
This policy addresses the requirements of the Federal Privacy Act of 1974 and amendments, regarding requests by the University for Social Security numbers (SSN) and provides guidelines for policy and procedures on the proper use and disclosure of the SSN to ensure that the Federal Privacy Act requirements are met.

II. Background
The Federal Privacy Act of 1974 and amendments establish guidelines under which any state agency may request Social Security number from individuals. Individuals may not be required to give their SSN unless specific to a Federal or State statute. Agencies may not deny any right, benefit or privilege to any individual because of their refusal to disclose their SSN. It is incumbent on the University to inform the individual whether the disclosure is mandatory or voluntary, by what statute or other authority, and what uses will be made of the Social Security number. (Reference A below)
The Social Security number was not designed to serve as a universal identification mechanism. Casual use of the SSN has led to the escalation of the crime of identity theft. With the SSN accessible to so many people, it is possible for someone to fraudulently use an individual's Social Security number to assume another identify and gain access to financial and other personal information, risking an individual's personal credit and confidentiality. For many years, SSN has been used as an identification number in many computer systems; giving access to private information and allowing an easy way to link database information. Federal Privacy Act compliance serves as a deterrent to identity theft and its consequences. It is the intent of the University to take the necessary precautions to protect the identity of all of its constituents.

III. Collection and Release of the Social Security Number

Student
The Board of Regents (BOR) supports the use of alternate identifiers for students as indicated below in the BOR policy manual. (Section 402.0305)
"The Social Security number shall be required from all entering students for a permanent and lasting record. When possible, an alternative number will be assigned and used by institutions for all purposes, which do not require the Social Security number. In no event shall grades be posted by using the Social Security number. The University System of Georgia is dedicated to insuring the privacy and proper handling of confidential information pertaining to students and employees."
GSW will request that a student provide a Social Security number at the time of application to the University. The Social Security number will not be used as the student ID number but will be provided to entities requiring Social Security number, including but not limited to the federal government for financial aid and Tax Relief Act (1997) reporting, United States Citizenship and Immigration Services (USCIS), Board of Regents of the University System of Georgia for statistical reporting purposes and as required by court order in accordance with the Family Educational Rights and Privacy Act. Beginning in fall 2005, information on collection and disclosure of a student's Social Security number can be found in the GSW Bulletin online at http://www.gsw.edu

Employee
GSW will require that an employee provide a Social Security number at the time of employment. The Social Security number will not be used as an Employee ID number for internal University uses, but will be provided to external entities requiring Social Security number, including but not limited to federal, state and local governments, insurance carriers, and retirement programs. Individuals who are affiliates or vendors will be required to provide a Social Security number for mandated tax reporting purposes.

IV. Regulations

  1. Systems purchased or developed by GSW will not use Social Security numbers as identifiers unless required by law or business necessity.
  2. All GSW employees, students and other individuals who require an identifying number will be assigned a unique identification number that is not the same as, or derived from, the individual's Social Security number.
  3. Systems purchased or developed by GSW will use Social Security numbers as data elements only, not as key identifiers.
  4. Systems purchased or developed by GSW will not display Social Security numbers visually, whether on computer monitors, or on printed forms or other system output, unless required by law or business necessity.
  5. Name and directory systems purchased or developed by GSW will be tied to an individual's unique identification number, not Social Security number.
  6. When databases require Social Security numbers, the database will automatically cross-reference between the Social Security number and other information through the use of conversion tables with systems or other mechanical mechanisms.
  7. No system or technology will be developed or purchased by GSW unless it is compatible with these regulations.

Reference. A

DISCLOSURE OF SOCIAL SECURITY NUMBER
Section 7 of Pub. L. 93-579 provided that: (a)(1) It shall be unlawful for any Federal, State or local government agency to deny to any individual any right, benefit, or privilege provided by law because of such individual's refusal to disclose his social security account number. (2) the (The) provisions of paragraph (1) of this subsection shall not apply with respect to - (A) any disclosure which is required by Federal statute, or (B) the disclosure of a Social Security number to any Federal, State, or local agency maintaining a system of records in existence and operating before January 1, 1975, if such disclosure was required under statute or regulation adopted prior to such date to verify the identity of an individual. (b) Any Federal, State, or local government agency which requests an individual to disclose his social security account number shall inform that individual whether that disclosure is mandatory or voluntary, by what statutory or other authority such number is solicited, and what uses will be made of it.

 

SSN Disclosure Statement

Student

Federal law recognizes the student's Social Security number (SSN) as personally identifiable information under the Family Education Rights and Privacy Act of 1974 (FERPA). However, the law allows GSW to request and to use this information in compliance with state and federal guidelines. While you are not required to provide your SSN to be considered for admission to GSW, you are strongly encouraged to do so, if you have one. Providing a SSN will speed up matching of materials such as transcripts and test scores with your application. A SSN is required if you are applying for financial aid for federal tax benefits, or for employment; it may be required for other purposes. The information may be disclosed only 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 purposes to improve instruction;
  • to collection agents in connection with university-related business;
  • pursuant to an order from a court of law;
  • other circumstances as required by state or federal law.

GSW is committed to ensuring the privacy and confidentiality of student records.

Employees & Affiliates

SSN required on HR forms for employees:
Federal tax regulations require us to obtain a SSN from every employee who is paid compensation. Employee Social Security numbers are maintained and used by the University for payroll and benefits purposes, to verify employment history, and are reported to Federal and state agencies on forms required by law or for benefits purposes. Except as mandated by law or as required by the Board of Regents of the University System of Georgia or as required for benefit purposes, the University will not disclose an employee's SSN to anyone outside the University without the employee's consent. Failure to provide a SSN may result in the withdrawal of an offer of employment and/or the denial of benefits. GSW is working to minimize the use of Social Security numbers within its business processes. For more information please refer to the GSW Social Security number policy.

SSN required by third party form (such as benefit form):
At times the University may provide you with forms on the behalf of benefit providers and other organizations. Many of these forms require your Social Security number. Private companies are within their rights to require your SSN in order to provide the requested service. These services typically include but are not limited to health and life insurance, retirement benefits, and employment verification. In addition, many State and Federal forms will also request your SSN. In addition to tax and other compensation-related forms these may include background checks for security sensitive positions, Board of Regents reports, and immigration-related documents among others. If you feel one of these third parties has misused your SSN, please refer the matter to the Director of Human Resources as well as the party in question.