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POL 2.270 Social Security Number Privacy Policy

The college shall obtain social security numbers from individuals for a valid business purpose only, and shall ensure to the extent practicable the confidentiality of social security numbers in its possession. The college prohibits unlawful disclosure of social security numbers and prescribes limits on who has access to information or documents that contain social security numbers. Documents containing social security numbers shall be properly disposed of, and the college provides penalties for violation of the privacy policy. This policy shall be published in readily accessible format in the policy and procedure manual and other similar documents as appropriate for ready access.

Approved December 19, 2005

PRO 2.270 – SOCIAL SECURITY NUMBER PRIVACY POLICY

  1. The college administrator over the office of the registrar is responsible for overseeing social security number usage for students enrolled at Kirtland Community College. The college administrator over operations of the business office is responsible for overseeing all other social security number usage for the college. These administrators control the social security number, and their approval is required to use the social security number on any new form in any format introduced within the respective areas of their responsibility.
  2. A college-wide unique identification number (UIN) will be individually assigned to all students, employees, and other associated in dividuals, such as contractors or consultants. The UIN will be considered a public piece of information. This UIN will be assigned at the earliest possible point of contact between the individual and the college. The UIN will be used in all electronic and paper data systems to identify, track, and service individuals associated with the college. It will be permanently and uniquely associated with the individual to whom it is originally assigned.
    1. The UIN is the property of Kirtland Community College, and its use and governance shall be at the discretion of the college, within the parameters of the law.
    2. The UIN is assigned, maintained and administered by the office of the registrar and the business office, according to their respective functions.
  3. Social security numbers will be electronically transmitted only through encrypted mechanisms.
  4. In the event of disposal, paper and electronic documents containing social security numbers will be shredded or otherwise disposed of in a secure fashion.
  5. Social security numbers will be released to entities outside the college only
    1. As allowed by law; or
    2. When permission is granted by the individual; or
    3. When the external entity is acting as the college’s contractor, and adequate security measures are in place to prevent unauthorized dissemination to unauthorized third parties; or
    4. The president, or his/her designee has directed under advice by legal counsel
  6. The social security number may continue to be stored as a confidential attribute associated with an individual. The social security number may be used as:
    1. Allowed by law;
    2. A means to identify individuals for whom a UIN is not known.
  7. Only college employees requiring access to social security numbers for the execution of their duties shall have such access. This policy does not preclude college employees from using the social security number as needed during the execution of their duties. The other aspects of this policy bind such usage.
  8. An employee or student who has substantially breached the confidentiality of social security numbers will be subject to disciplinary action or sanctions up to and including termination or expulsion in accordance with college policies and procedures.