Standard 13: Use and Protection of Social Security Numbers

The University recognizes the special risks associated with the collections, use, and disclosure of social security numbers. Accordingly, the requirements of this section are to apply to all social security numbers contained in any medium, including paper records that are collected, maintained, used, or disclosed by the university.

1. The University shall discontinue the use of all or part of the social security number as an individual's primary identification number unless required or permitted by law. The social security number may be stored as a sensitive attribute associated with an individual only if use of the social security number is essential for the performance of a mission related duty.
2. If the maintenance and use of social security numbers is permitted, but not required by applicable law, the University shall permit the maintenance and use of social security numbers only as reasonably necessary for the proper administration or accomplishment of their respective business, governmental, educational and medical purposes, and only if the University determines that the benefit outweighs the potential risk created by the particular maintenance or use of the social security number. Potential purposes may include:
   1. Use as a means of identifying an individual for whom a unique identification number is not known;
   2. Use for internal verification or administrative purposes where it is not feasible to use some other identifier; and
   3. Use for verification or administrative purposes by a third party or its agent in conducting business on behalf of UNF, where the third party or agent has contracted to comply with the safeguards described in Standard 11 - Safeguarding Data.
3. Except in those instances in which UNF is legally required to collect a social security number, an individual shall not be required to disclose all or part of his or her social security number, nor shall the individual be denied access to the services at issue if the individual refuses to disclose his or her social security number. An individual, however, may volunteer his or her social security number. A request by UNF that an individual provide his or her social security number for verification of the individual's identity where the social security number has already been disclosed does not constitute a disclosure for purposes of this Standard. Questions about whether a particular use is required by law should be directed to the UNF Privacy Officer, who will consult with the office of the General Counsel with respect to the interpretation of law.
4. UNF may, but is not required to, designate only selected offices and positions as authorized to request that an individual disclose his or her social security number.
5. UNF shall assign a unique identifier (e.g., the UNF ID or N-number) for each applicant, student, employee, insured dependent, research subject, patient, alumnus, donor, contractor, and other individuals, as applicable, at the earliest possible point of contact between the individual and the University for use in lieu of a social security number. The unique identifier shall:
   1. Be used in all electronic and paper information systems to identify, track, and serve these individuals;
   2. Be permanent and unique within the university as applicable, and remain the property of, and subject to the rules of, UNF; and
   3. Not be derived from the social security number of the individual.
6. UNF shall provide notice to individuals when they collect social security numbers.
   1. Each time the University requests that an individual initially disclose his or her social security number, it shall provide the notice required by Section 7 of the Federal Privacy Act of 1974 (5 U.S.C. § 552a), which requires that the individual be informed whether the disclosure is mandatory or voluntary, by what statutory or other authority the number is solicited, and what uses will be made of it. A subsequent request for production of a social security number for verification purposes does not require the provision of another notice.
      1. The notice shall use text as may be approved by the UNF office of the General Counsel.
      2. Notices shall be in writing if possible. If a verbal notice is required, such notice shall be promptly documented.
   2. Employees may not seek out or use social security numbers relating to others for their own interest or advantage.
7. The public display of social security numbers is prohibited.
   1. Grades may not be publicly posted or displayed in a manner in which all or any portion of either the social security number or the unique identifier identifies the individual associated with the information.
   2. Social security numbers shall not be displayed on documents that are accessible to individuals who do not have a business reason to access the numbers. This section does not prohibit the inclusion of the social security number on transcripts or on materials for Federal or State data reporting requirements.
   3. If an organizational unit must send materials containing social security numbers through the physical mail, the social security number must be placed in an envelope in such a way that ensures that no part of the social security number is visible from the outside.
   4. Employees are prohibited from sending social security numbers over the internet or by email unless the connection is secured, or the social security number is encrypted or otherwise secured. The University shall require employees sending social security numbers by fax to take appropriate measures to protect the confidentiality of the fax (such measures may include confirming with the recipient that the recipient is monitoring the fax machine).
   5. UNF shall not print or permit a third party acting on behalf of the institution to require that an individual's social security number be printed on a card or other device required to access a product or service provided by, on behalf of, or through the institution.
8. All information systems acquired or developed must comply with the following:
   1. The information system must use the social security number only as a data element or alternate key to a database and not as a primary key to a database;
   2. The information system must not display social security numbers visually (such as on monitors, printed forms, system outputs) unless required or permitted by law or permitted by this standard;
   3. Name and directory systems must be capable of being indexed or keyed on the unique identifier, once it is assigned, and not on the social security number; and
   4. For those databases that require social security numbers, the databases may automatically cross-reference between the social security number and other information through the use of conversion tables within the information system or other technical mechanisms.