Social Security Number Policy

You must provide a Social Security Number (SSN) in order for SCP Housing Authority to process and maintain your Public Housing. SCP Housing Authority is required by Federal law to report Social Security Numbers to Federal and state agencies on forms required by law. SCP Housing Authority will not disclose a recipient’s SSN without the consent of the recipient to anyone outside SCP Housing Authority except as mandated by law

Objectives

SCP Housing Authority recognizes that it collects and maintains confidential information relating to its tenants, landlords, employees, and individuals associated with SCP Housing Authority and is dedicated to ensuring the privacy and proper handling of this information. This should be understood as the spirit of this policy statement. The primary purpose of this Social Security number policy is to ensure that the necessary procedures and awareness exists to ensure that SCP Housing Authority employees, tenants and landlords comply with all Information Security Protocols. This policy also exist to ensure:

1. Broad awareness of the confidential nature of the Social Security number;
2. Reduced reliance upon the Social Security number for identification purposes;
3. A consistent policy towards and treatment of Social Security numbers throughout the University; and
4. Increased confidence by students and employees that Social Security numbers are handled in a confidential manner.
5. To ensure compliance with Louisiana Identity Protection and Identity Theft Laws

I.Guidelines / Regulations

I.1. SCP Housing Authority, will assign to an existing administrator the responsibility of overseeing Social Security number usage within the faciity. These administrators control the Social Security number and their approval will be required to use the Social Security number in any new electronic system. Specific responsibilities are spelled out in the Implementation section below (II.1). SCP Housing Authority is free to choose an administrator that best fits its individual administrative model. The SCP Housing Authority Administration administrator will represent SCP Housing Authority and provide an institutional perspective to all dialog between these administrators.

I.2.All SCP Housing Authority forms and documents that collect Social Security numbers will use the language included below (II.2) and will indicate whether request is voluntary or mandatory. Forms and documents will be modified on an as reprinted basis with full compliance.

I.3.Paper and electronic documents containing Social Security numbers will be disposed of in a secure fashion.

I.4.Except where the SCP Housing Authority is legally required to collect a Social Security number, individuals will not be required to provide their Social Security number, verbally or in writing, at any point of service, nor will they be denied access to those services should they refuse to provide a Social Security number. However, individuals may volunteer their Social Security number if they wish as an alternate means of locating a record.

I.5.Social Security numbers will be released by the SCP Housing Authority to entities outside SCP Housing Authority only

I.6.1.As allowed by law;

OR

I.6.2.When permission is granted by the individual; OR

I.6.3.When the external entity is acting as the SCP Housing Authority ‘s contractor or agent and adequate security measures are in place to prevent unauthorized dissemination to third parties; OR

I.6.4.When Legal Counsel has approved the release.

The Social Security Number Coordinators will maintain the list of approved entities.

I.7.The Social Security number may continue to be stored as a confidential attribute associated with an individual. The Social Security number will be used as

I.7.1.Allowed by law;

I.8.This policy does not preclude, if a primary means of identification is unavailable, SCP Housing Authority employees from using the Social Security number as needed during the execution of their duties. The other aspects of this policy statement bind such usage.

I.9.Social Security numbers will only be collected in circumstances where the collection is mandated by a government agency.

I.10.Individuals that are identified as having access to SSNs in the course of performing their duties must be provided with training materials on the proper handling of SSNs.

I.11.Only employees that are authorized by the Social Security Number Coordinators are permitted to have access to SSNs.

II.Implementation

II.1. SCP Housing Authority office will have the responsibility to:

II.1.1.Oversee and ensure the implementation of this policy statement;

II.1.2.Provide support, guidance, and problem resolution for offices working with Social Security numbers;

II.1.3.Serve as an intermediary between SCP Housing Authority and SCP Housing Authority Legal Counsel when an opinion on the release or exchange of Social Security numbers is required;

II.1.4.Maintain a list of entities, approved by Legal Counsel, to which Social Security numbers may be released;

II.1.5.Coordinate with the other campus Social Security number offices to create an electronic system to function as the central distribution mechanism for information pertaining to Social Security number usage at SCP Housing Authority;

II.1.6.Coordinate with Board of Directors to produce a SCP Housing Authority educational program to train employees on the handling of Social Security numbers and make students aware of their rights and responsibilities with regard to Social Security numbers;

II.1.7.Meet regularly to resolve differences in implementation procedure to ensure uniformity across SCP Housing Authority in implementation details, and an adherence to the spirit of this policy statement;

II.1.8.Authorize the use of Social Security numbers in all electronic systems. Systems collecting, storing, or using Social Security numbers must receive explicit permission to do so from the appropriate SSN Coordinator. Business cases supporting such requests must include the legal or functional requirement for using the SSN, detailed descriptions of the security precautions planned for such systems, and how prepared the unit is to cover the costs for any potential data breach.

II.2.Employee

“Use of Employee Social Security numbers: SCP Housing Authority is required by federal law to report income along with Social Security numbers (SSNs) for all employees to whom compensation is paid. Employee SSNs are maintained and used by SCP Housing Authority for payroll, reporting and benefits purposes and are reported to federal and state agencies in formats required by law or for benefits purposes. SCP Housing Authority will not disclose an employee’s SSN without the consent of the employee to anyone outside SCP Housing Authority except as mandated by law or required for benefit purposes.”

II.3 ACT Technologies in conjunction with SCP Housing Authority will, as part of its data management strategy, develop a set of guidelines addressing the handling of Social Security numbers in electronic systems. Adherence to these guidelines in all future development will be considered a requirement of this policy statement. These guidelines will explicitly address:

II.3.1.The display of Social Security numbers on computer terminals, screens, and reports;

II.3.2.The security protocol required to access Social Security numbers when they are included in part of an electronic database;

II.3.3.Alternate mechanisms for integrating data other than the use of Social Security number;

II.3.4.The legal requirement to maintain confidentiality of the Social Security numbers imposed by the Privacy Act of 1974;

II.3.5.Obtaining permission to include the Social Security number in a system from the administrator designated in section I.1.

III.Enforcement

III.1. SCP Housing Authority will be responsible for monitoring compliance with this policy.

III.2.An employee who has substantially breached the confidentiality of Social Security numbers may be subject to disciplinary action or sanctions up to and including discharge or dismissal in accordance with SCP Housing Authority policy and procedures.