The Official Web Site for the Archdiocese of Detroit

Home / Offices & Ministries / Human Resources / Social Security Number Policy

Safeguarding Social Security Numbers

Effective March 1, 2005 - Michigan Social Security Number Privacy Act that took effect. Parishes, Schools and Organizations must protect the social security numbers of employees, staff, students, parents, parishioners, volunteers, independent contractors, etc. and eliminate the unnecessary use, display, and transmission of the information.

Social Security Number Policy for Parishes and Schools

Reference this page: www.aodonline.org/SSNpolicy

Questions, concerns, or to request documents contact hr@aod.org / (313) 237-5947.

Responsibility

Responsibility for adherence to the Policy for Safeguarding Social Security Number Information rests with individual Organizations and Persons. Persons who disregard this policy do so at their own risk and will be held responsible by the Parish and others. Corrective action may take various forms depending on the specific nature and circumstances of the offense and the extent of the harm.

Prohibited Use of Social Security Numbers

In compliance with the Social Security Number Privacy Act, Parish will restrict the use, display, and transmission of social security numbers, except as needed for legitimate business, administrative or legal purposes or as authorized or required by state or federal statute, rule, or regulation, by court order or rule, or pursuant to legal discovery or process.

Unauthorized and Unlawful Disclosure

Parish and Persons are prohibited from the unauthorized and unlawful disclosure of social security numbers.
No Public Display

Parish and Persons will not publicly display more than four sequential digits of an individual's social security number. "Public display" means to exhibit, hold up, post, or make visible or set out for open view, including, but not limited to, open view on a computer device, computer network, website, or other electronic medium or device, to members of the public or in a public manner.
No Use on Identification Badge

Parish and Persons will not use more than four sequential digits of an individual's social security number on any identification badge or card.
Internet and Computer Access
1. Parish and Persons will not use or transmit more than four sequential digits of an individual's social security number over the Internet or computer system or network unless the connection is secure or the transmission encrypted.
2. Parish and Persons will not use or transmit more than four sequential digits of an individual's social security number or require the use of more than four sequential digits of an individual's social security number to gain access to an Internet Web site or computer system or network unless the connection is secure, the transmission encrypted, or a password or other unique personal identification or authentication device is also required to gain access to the Internet web site or computer system or network.
Mailed Documents
1. Parish and Persons will not include more than four sequential digits of an individual's social security number in or on any document or information mailed or otherwise sent to an individual if the numbers are visible on (or, without manipulation from) the outside of the envelope or packaging. "Mailed" means delivered by the United States mail or other delivery service that does not require the signature of the recipient indicating actual receipt. This definition includes use of a courier service such as UPS or FedEx if delivery does not require the individual to sign upon delivery.
2. Parish and Persons will not include more than four sequential digits of an individual's social security number in any document or information mailed, unless one or more of the following apply:
  1. State or federal law, rule, regulation, or court order or rule authorizes, permits, or requires that a social security number appear in the document or information;
  2. The document or information is sent as part of an application or enrollment process initiated by the individual;
  3. The document or information is sent to establish, confirm the status of, service, amend, or terminate an account, contract, policy, or employee or health insurance benefit or to confirm the accuracy of a social security number of an individual who has an account, contract, policy, or employee or health insurance benefit;
  4. The document or information is mailed by or at the request of the individual (or his/her parent or legal guardian) whose social security number appears in the document or information; or
  5. The document or information is mailed in a manner or for a purpose consistent with the privacy requirements of certain federal and state laws.
3. Parish and Persons may, however, include more than four sequential digits of an individual's social security number in any document or information mailed for an administrative purpose, in the ordinary course of business, to do any of the following:
  1. Verify an individual's identity, identify an individual, or do another similar administrative purpose related to an existing or proposed account, transaction, product, service, or employment;
  2. Investigate an individual's claim, credit, criminal, or driving history;
  3. Detect, prevent, or deter identity theft or another crime;
  4. Lawfully pursue or enforce a person's legal rights, including, but not limited to, an audit, collection, investigation, or transfer of a tax, employee benefit, debt, claim, receivable, or account or an interest in a receivable or account; or
  5. Provide or administer employee or health insurance or membership benefits, claims, or retirement programs or to administer the ownership of shares of stock or other investments.
General Exception

None of the above prohibitions are applicable if the use of more than four sequential digits of an individual's social security number is authorized or required by state or federal statute, rule, regulation, by court order or rule, or pursuant to legal discovery or process.
Securing Documents with Social Security Numbers
1. To the extent practical, Parish and Persons are required to ensure the confidentiality of social security numbers in their possession.
2. All documents with social security numbers must be kept in a secured, locked, cabinet or safe, with access limited to those Persons who have valid, demonstrable need to access the information for legitimate business, administrative and/or legal purposes.
Retention and Disposal of Documents with Social Security Numbers
1. All documents/records with social security numbers must be retained only when necessary, according to the Archdiocese of Detroit Record Retention Policy (as stated in the Financial Policies & Procedures Manual).
2. When such documents/records are disposed of, they must be shredded using cross-cut paper shredders. Under no circumstances are documents/records containing social security numbers to be disposed of without shredding.
Penalties
1. To minimize possible damage, Persons should immediately report any act by themselves or others which may have resulted in a violation of this policy or any other suspected violation of this policy to the Pastor or Head of the Organization, (e.g., Principal of a school), or Director of the Archdiocese of Detroit Department of Finance and Administration at (313) 237-5834. The Organization will investigate. Where appropriate, the Organization may notify law enforcement. Persons found to have violated this policy will be sanctioned. In determining the sanction, the Organization will take into consideration whether the Person promptly self-reported his/her own actions.
2. A knowing violation of the Social Security Number Privacy Act is a misdemeanor punishable by no more than 93 days in jail, a fine of not more than $1,000, or both.
3. In addition, knowing violations may result in civil liability, including actual damages or $1,000, whichever is greater, plus reasonable attorney fees.
Preventing Identity Theft in the Workplace
1. To prevent identity theft, Parish will hire and retain honest, ethical, responsible and productive employees.
2. Parish will use effective pre-employment screening and verification processes which are critical to limiting the risk of identity theft in the workplace. In many instances, pre-screening alerts Parish to an applicant's criminal history, risky driving record, and/or falsification of applicant information. Pre-screening may include, but is not limited to, conducting criminal background checks, contacting references, contacting educational institutions and prior employers listed on applications and resumes, requiring applicants to take skills and knowledge testing, etc.