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Social Security Privacy Policy
Approved: 12/15/2005

I. Policy. It is the policy of the Ypsilanti District Library to ensure to the extent practicable the confidentiality of employees’ Social Security Numbers in accordance with the requirements of the Michigan Social Security Number Privacy Act.

II. Implementation and Enforcement. The effective date of this Policy is January 1, 2006. The Ypsilanti District Library shall establish rules and regulations to implement this policy and ensure that; 1) access to information or documents containing Social Security Numbers is limited; 2) documents containing Social Security Numbers are disposed of properly, and; 3) this policy is published in the appropriate handbooks, manuals, or other similar documents.

III. Permitted Uses of Social Security Numbers. The employer may use Social Security for the following reasons:

a. Use Authorized or Required by Law. The Ypsilanti District Library 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. Primary Account Number. The Ypsilanti District Library may use an individual’s Social Security Number as the primary account number for the purposes itemized in section (c) below.

c. Administrative Use in the Ordinary Course of Business. The Ypsilanti District Library may use Social Security Numbers:

  • to verify the individual’s identity, to identify an individual, or for similar administrative purposes related to employment;
  • to investigate an individual’s claim, credit, criminal or driving history;
  • to detect, prevent, or deter identity theft or other crimes;
  • to lawfully pursue or enforce legal rights, such as for audit, collection, investigation or transfer of an employee benefit, or a claim, debt, 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.

IV. Restrictions on Use and Disclosure. The Ypsilanti District Library will comply with the following restrictions on the uses and disclosures of Social Security Numbers:

a. Public Displays. The Ypsilanti District Library will not publicly or visibly display more than 4 sequential digits of a Social Security Number on property or on any Ypsilanti District Library identification badge or similar item.

b. Computer Use. The Ypsilanti District Library will not require employees to use or transmit 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 Ypsilanti District Library will not require employees to use or transmit 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 .

    • The Ypsilanti District Library will not include more than 4 sequential digits of Social Security Numbers on the outsides of envelopes or packages, and will not mail documents or information containing more than 4 sequential digits of Social Security Numbers if those numbers are visible without manipulation from the outside of the envelope or package.
    • The Ypsilanti District Library will not include 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 III (c) 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, 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. The Ypsilanti District Library limits access to Social Security Numbers to those employees whose job duties require that they use this information in connection with Ypsilanti District Library business. The employees who have access to Social Security Numbers are those who work in the following areas:

    • Human Resources
    • Benefits Administration
    • Computer and Information Technology
    • Executive Management

Documents and electronic files containing Social Security Numbers will be maintained in confidential manner, and will not be disclosed to persons other than those working in the specified areas.

All employees in the designated areas will be provided training on the specific requirements of the Michigan Social Security Number Privacy Act and the provisions of this Policy.

e. Disposal of Documents and Data. The Ypsilanti District Library 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.

f. Public Records. Where a Social Security Number is contained within a document subject to disclosure under the Freedom of Information Act, the Social Security Number shall be redacted.

g. Federal Privacy Act. The Ypsilanti District Library, upon collecting a Social Security Number, shall inform the individual of:

i. the purpose for the collection;
ii. the intended use of the Social Security Number;
iii. whether the law requires the number to be provided, and;
iv. the consequences of not providing the number.

V. Penalties. Any employee who has intentionally violated the Social Security Number Privacy Act or this Policy is subject to disciplinary measures up to and including discharge.