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Date of Last Update
- Senior Leadership Team
Office of General Counsel
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Applicability This policy applies to all members of
the GVSU community including faculty, staff and students.
Access to Social Security Numbers. GVSU restricts
access to information or documents containing social security
numbers to members of the GVSU community who have a legitimate
university business reason to access such information or documents.
The heads of departments having access to records containing social
security numbers shall determine which other personnel within their
departments have a legitimate reason in the University’s ordinary
course of business to have access to such social security numbers.
Personnel using such records containing Social Security Numbers must
take appropriate steps to secure such records when not in immediate
Confidentiality of Social Security Numbers. Members
of the GVSU community shall maintain the confidentiality of
university information or documents containing social security
numbers consistent with the law and this policy. No person shall
knowingly obtain, store, transfer, use, disclose, or dispose of
social security numbers except in accordance with the law and this
Obtaining Social Security Numbers. Social security
numbers should be collected only where required or permitted by
federal and state law or for legitimate university business reasons
consistent with law and policy.
Public Display. No more than four sequential digits
of a social security number shall be on public display. Public
display means to post, make visible, or set out for open view to
members of the public or in a public manner. This includes open view
on a computer screen or device.
Account Numbers. As of the effective date of this
policy, GVSU has undertaken a systematic process to eliminate social
security numbers as identification numbers for all current members
of the GVSU community. Once assigned an alternative identification
number, neither the University nor the individual may return to the
use of a social security number as an identification number for that
Mailed Documents. Documents containing more than
four sequential digits of a social security number shall only be
sent by mail in cases where state or federal law, rule, regulation,
or court order or rule authorizes, permits or requires that a Social
Security number appear in the document, the document is sent as part
of an application or enrollment process initiated by the individual,
at the request of or with the permission of the individual, their
parent or guardian, or with regard to an employee or heath insurance
benefit. Documents containing more than four sequential digits of a
social security number, that are properly sent through the mail,
shall not reveal the number through the envelope window or otherwise
be visible from the outside of the envelope or package. Mail
includes delivery by regular US mail, campus mail, or any other
delivery service that does not require the signature of the
recipient indicating actual receipt.
Freedom of Information Act Requests. Where more
than four sequential digits of a social security number are
contained within a document subject to release under the Freedom of
Information Act, the social security number shall be redacted or
otherwise rendered unreadable before the document or copy of the
document is disclosed. Any request for disclosure of documents under
the Freedom of Information Act shall be first referred to the
Division of Legal, Compliance and Risk Management.
Storage of Documents. All documents containing
social security numbers shall be stored in a physically secure
manner. Social security numbers shall not be stored on computers or
other electronic devices that are not secured against unauthorized
Disposal of Documents. Documents containing social
security numbers will be retained in accordance with the
requirements of state and federal law and consistent with the
legitimate business needs of GVSU. At such time as documents
containing social security numbers may be disposed of, such disposal
shall be accomplished in a manner that protects the confidentiality
of the Social Security numbers, such as by shredding.
Unauthorized Use or Disclosure of Social Security
Numbers. GVSU shall take reasonable measures to enforce
any known violations. Anyone who knowingly obtains, uses or
discloses social security numbers for unlawful purposes or contrary
to the requirements of this policy, state or federal law, shall be
subject to discipline up to and including discharge for employees or
expulsion for students consistent with existing disciplinary
policies. Additionally, certain violations of the Act carry criminal
and/or civil sanctions. GVSU will cooperate with the appropriate law
enforcement or administrative agencies in the apprehension and
prosecution of any person who knowingly obtains, uses or discloses
Social Security numbers for unlawful purposes.
- Lawful and Required Use. Nothing in this policy is designed to prohibit the collection, retention or transmission of documents or records containing Social Security numbers as required or permitted by state or federal law, rule or regulation, at the request of or with permission of the individual, for administrative use in the ordinary course of business to verify identity, to pursue legal rights of GVSU, or to provide or administer employee benefits such as health or retirement benefits.