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WCC SOCIAL SECURITY NUMBER PRIVACY POLICY

The purpose of this policy is to comply with the State of Michigan Public Act 454 of 2004 to establish the social security number privacy regulations.

General Provisions
  • WCC shall, to the extent practicable, ensure the confidentiality of social security numbers and limit who has access to information or documents that contain social security numbers.

  • All documents and records containing social security numbers shall be kept in a secure environment.

  • All employees that use or have access to any employee or student social security number and information shall be held to the highest degree of confidentiality.

  • Access to information or documents that contain social security numbers shall be limited to employees of the College with a need to know.

  • Any documents that contain social security numbers shall be properly shredded or otherwise destroyed prior to disposal.

  • No employee is permitted to access or use social security numbers without express permission of the College.

  • Only personnel authorized through Banner or Oracle security may access internal or external records and documents containing employee social security number and identification information.

  • Violation of this policy may lead to discipline up to and including termination of employment.

  • Violation of the provisions of Public Act 454 of 2004 may subject the violator to criminal charges or civil liability.

Employee Social Security Number Protection and Disposal

It is WCC policy to use the randomly assigned employee identification number rather than any part of the employee's social security on all internal and external communications. However, use of the social security number is necessary in some instances. When use of some or all the social security number is necessary, no person shall intentionally do any of the following:
  • Publicly display all or more than 4 sequential digits of the social security number,

  • Use all or more than 4 sequential digits of the social security number as the primary account number for an individual, other than exceptions in the Public Act,

  • Visibly print all or more than 4 sequential digits of the social security number on any identification badge or card, membership card, or permit or license,

  • Require an individual to use or transmit all or more than 4 sequential digits of his or her social security number over the internet or a computer system or network unless the connection is secure or the transmission is encrypted,

  • Require an individual to use or transmit all or more than 4 sequential digits of his or her social security number to gain access to an internet website or a computer system or network unless the connection is secure, the transmission is encrypted, or a password or other unique personal identification number or other authentication device is also required to gain access to the internet website or computer system or network.

  • Include all or more than 4 sequential digits of the social security number in or on any document or information mailed or otherwise sent to an individual if it is visible on or, without manipulation, from outside of the envelope or packaging.

  • Include all or more than 4 sequential digits of the social security number in any document or information mailed to a person, unless any of the exceptions in the Public Act apply.

All documents and records containing Social Security numbers and information will be kept in a secure environment with need to know access by authorized personnel only. When necessary documents containing this and other confidential information will be properly destroyed through shredding or other means before disposal.

If you have any questions regarding employee social security number privacy and security please see the FAQ on the Human Resources website or contact the Human Resources office (734 -973-3497).

Vendor Social Security Number Protection and Disposal

In order to ensure proper payment of outside vendors, it is necessary, in some instances, for the Financial Services department to collect the social security numbers of individual vendors. In these situations, the same guidelines written above for use or display of employees' social security numbers shall apply.

Student Social Security Number Protection and Disposal

WCC protects the student's right of privacy of information and recognizes the importance of maintaining the confidentiality of student records while enabling the effective functioning of the College. It is WCC policy to use the randomly assigned student identification number instead of the student's social security number on all internal and external communication.

In some instances, it is necessary to obtain and use a student's social security number. In those instances, the same guidelines written above for use or display of employees' social security numbers shall apply.

Social security numbers are collected from all students and are currently used for:
  • financial aid

  • specific reporting functions as required by the State and Federal government

  • Veterans' certification

  • GED testing

  • reporting to the National Student Clearinghouse used for attendance verifications, degree reporting, and loan tracking

The Student ID number may be used interchangeably for the social security number whenever the student registers for classes, makes a payment, or other internal functions using My WCC. When the student gives a social security number, the Student ID will print on any hard copy material such as schedules, rosters, bills, etc. Originals or copies of materials with a Student ID number or social security number are retained in a secure area or shredded or otherwise destroyed before disposal.

AUTHORIZATION OF STAFF POLICY

President's authorization: Larry Whitworth

Date authorized: December 20, 2005     Effective Date: December 20, 2005

12/21/2005




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