Social Security Number Privacy Policy
Statement of Purpose:
Benefit Advisors, Inc. (BA) is committed to maintaining the confidentiality of social security numbers it collects with respect to employees, client participants and individuals associated with the company. Effective January 1, 2006, BA is required by the Michigan Social Security Number Privacy Act, Public Act 454 of 2004, MCL 445.81 et seq., (the "Act") to create a privacy policy which applies to BA officers, and employees.
It is the policy of BA to protect the confidentiality of social security numbers obtained in the ordinary course of its business. BA restricts access to information or documents containing social security numbers to employees who have a legitimate business reason to access such information or documents. No employee shall knowingly obtain, store, transfer, use, disclose, or dispose of a social security number that BA obtains or possesses except in accordance with the Act and this privacy policy. Personnel using records containing social security numbers must take appropriate steps to secure such records when not in immediate use.
Procedure:
1. Authorized collection and use of social security numbers. This Policy does not prohibit the use of social security numbers where the use is authorized or required by state or federal statute, rule, regulation, or court order or rule, or pursuant to legal discovery or process.This Policy also does not prohibit the use of social security numbers for criminal investigation purposes or the provision of social security numbers to a Title IV-D agency (child support/support orders), law enforcement agency, court, or prosecutor as part of a criminal investigation or prosecution.
Other legitimate reasons for collecting a social security number include, but are not limited to:
- Applicants for employment may be required to provide a social security number for purposes of a pre-employment background check.
- Copies of social security cards may be obtained for purposes of verifying employee eligibility for employment.
- Social security numbers may be obtained from employees for tax reporting purposes, for new hire reporting or for purposes of enrollment in any BA employee benefit plans.
- Social security numbers may be obtained from creditors, contractors or vendors for tax reporting purposes.
- Social security numbers may be obtained client participants for purposes of enrollment in any client Fringe Benefit Plan.
2. Prohibited use or display of social security numbers.
a. Public Display. A social security number shall not be placed on identification cards, badges, time cards, employee rosters, bulletin boards, permits, licenses or any other materials or documents designed for public display. Documents, materials or computer screens that display all or more than four sequential digits of a social security number shall be kept out of public view at all times.
b. Account Numbers. All or more than four sequential digits of a Social Security number shall not be used as a primary account number for an individual.
c. Mailed Documents. BA and client documents containing all or more than four sequential digits of a Social security number shall only be sent in cases where state or federal lwa, rule, regulation, or court order or rule authorizes, permits or requires that a Social security number appear in the document. Documents containing all or more than four sequential digits of a social security number, that are sent through the mail, shall not reveal the number through the envelope window or otherwise be visible from outside the envelope or package.
d. Computer Transmission. All or more than four sequential digits of a social security number shall not be used or transmitted on the Internet or on a computer system or network unless the connection is secure or the transmission is encrypted.
e. Storage. All documents containing social security numbers shall be stored in a physically secure manner. Social security numbers shall not be stored on computers or other electronic devices that are not secured against unauthorized access.
f. Disposal. Documents containing social security numbers will be retained in accordance with the requirements of state and federal laws and BA's and client record retention policy. At such time as documents containing social security numbers may be disposed of, such disposal shall be accomplished in a manner that protects the confidentiality of the social security numbers, such as shredding.