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2315 R&P 3015 R&P 4015 R&P 6315 R&P |
COLLECTION, USE, AND RELEASE OF SOCIAL SECURITY NUMBERS AND OTHER
PERSONAL IDENTIFYING INFORMATION |
2315 R&P 3015 R&P 4015 R&P 6315 R&P |
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In accordance with applicable
laws, the collection and use of social security numbers by school system
employees shall be strictly limited to those circumstances in which the
collection is expressly authorized by law or is imperative for the
performance of the schools system’s duties.
Departments and/or employees who must use social security numbers and
other personal identifying information to perform their job functions must
have authorization from the Superintendent or designee to collect or access
this information. Employees who are
granted such authorization are required to take appropriate measures as
developed by the school system to provide for the confidentiality,
protection, and security of the information in their possession. The collection, use, and release
of student social security numbers, personal identifying information, and
other confidential records shall also be in accordance with Board Policy 6300
Maintenance, Review, and Release of
Student Records. In an effort to protect employees
and students from the improper release and/or sharing of sensitive personal,
financial, medical, and familial information, the following provisions have
been establish. |
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2315.1 3015.1 4015.1 6315.1 |
Collection |
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A. |
The school
system may not collect a social security number from an individual unless it
is authorized by law or it is otherwise imperative for the performance of the
school system’s duties and the need has been clearly documented. Collection of social security numbers by
the school system is authorized by law only in a few circumstances,
including: |
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1. |
For the
administration of federal and state income taxes. |
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2. |
For Free
and Reduced Lunch applications. |
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3. |
When the
school system maintained a system of records before January 1, 1975, and the
disclosure of the social security number was required to verify the identity
of an individual. |
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B. |
Social
security numbers shall only be collected upon the prior written approval by
the Superintendent or designee.
Requests for collection of social security numbers must be made in
writing to the Superintendent or designee and must include a statement of the
purpose for which the social security number will be collected. |
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C. |
The
collection of social security numbers is subject to numerous
requirements. The school system must: |
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1. |
Provide an
individual, upon request, with a statement of the purpose for which the
social security number will be used prior to or at the time of collection. |
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2. |
Use the
social security number for the stated purpose only. |
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3. |
Segregate
collected social security numbers on a separate page from the rest of the
record or as otherwise appropriate in order that the number may be easily
redacted when responding to a valid public records request. |
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D. |
Any form
requiring a social security number that is created and/or initiated by the
school system must include language that states the reason the social
security number is collected, the authority for collecting the number, and
whether the disclosure is mandatory or voluntary. The school system will provide the
appropriate language to be used. |
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1. |
Any form
falling under this category must be approved by the Assistant Superintendent
of Human Resources for employee records or the Assistant Superintendent of
Student Support Services for student records prior to its use. |
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2. |
Forms that
are created and/or generated from
state or federal agencies (i.e., applications, workers’ compensation,
disability, retirement, unemployment,
etc.) are exempt from this approval process. |
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2315.2 3015.2 4015.2 6315.2 |
Disclosure |
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A. |
The school system may not
intentionally communicate or otherwise make available to the general public
an individual’s social security number or other “identifying
information.” Personal identifying
information includes passwords; employer taxpayer identification numbers;
drivers license, state identification card, or passport numbers (except when
the drivers license number appears on law enforcement records); employee
numbers, checking,
savings, credit card, and debit card numbers; any PIN code, digital
signature, or other information that can be used to access an individual’s
financial resources; and biometric data and fingerprints. |
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B. |
The school
system may disclose social security numbers and other identifying information
in the following instances: |
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1. |
To another
government entity if it is necessary to perform its duties. |
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2. |
Pursuant
to court order, warrant, or subpoena. |
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3. |
For public
health purposes pursuant to Chapter 130A. |
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C. |
Effective
July 1, 2007, the school system may not: |
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1. |
Intentionally
print or imbed a social security number on any card required for an
individual to access services. |
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2. |
Require an
individual to transmit a social security number over the internet unless the
connection is secure or the social security number is encrypted. |
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3. |
Require an
individual to use a social security number to access a web site unless a password or unique PIN is also
required to access the web site. |
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4. |
Print an
individual’s social security number on materials that are mailed to the individual unless state or federal law
requires that the social security number be on the document mailed. A social security number may not be printed
on a postcard or be visible through an
envelope without the letter being opened. |
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2315.3 3015.3 4015.3 6315.3 |
Authorization
to Access Collected Data |
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Access to data that contains
social security numbers or personal identifying information in electronic or
hard copy form is by authorization of the Superintendent or his designee only
and must be done in writing on the Authorization to Access form attached to
this R&P to be housed at the employee’s work location. Should an employee’s job responsibilities
change or should the employee transfer to another position in the school
system, the previous authorization will expire and the employee will need to
request authorization associated with his/her new position. |
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2315.4 3015.4 4015.4 6315.4 |
Confidential
Transmission of Social Security Numbers |
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When a social security number must
be reflected on a document and sent to a school system department, that
document must be placed in a sealed envelope addressed to a particular
individual and marked CONFIDENTIAL. If
the department has a designated colored envelope, then all written
communication with that department shall be placed in that colored envelope
for proper protection and transfer of information. |
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2315.5 3015.5 4015.5 6315.5 |
Storage of Social Security Numbers |
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A. |
Any file that
is created for the purpose of housing information that pertains to an
employee or student and contains that employee’s or student’s social security
number must be stored in a secure and locked
area at all times. |
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B. |
Copies of
records that contain social security numbers shall not be made without the
proper authorization or as allowed by law. |
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2315.6 3015.6 4015.6 6315.6 |
Training |
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It shall be
the responsibility of the Superintendent or designees to inform school system employees regarding this
policy. |
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2315.7 3015.7 4015.7 6315.7 |
Notice of a Security Breach |
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In the event of a security breach,
the school system will comply with the provisions outlined in N.C.G.S.
§75-65. |
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Adopted: June 14, 2007 |
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