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2005-99(b) CITY OF MUSKEGON Social Security Number Privacy Policy Effective Date: January 1, 2006 I. Purpose Pursuant to the Michigan Social Security Number Privacy Act, it is the policy of the City of Muskegon to protect the confidentiality of social security numbers. No person shall knowingly acquire, disclose, transfer, or unlawfully use the social security number of any employee or other individual unless in accordance with the procedures and rules established by this policy. Il. Administrative Procedures/Rules: A. Public Display More than 4 sequential digits of a social security number shall not be placed on identification cards, badges, time cards, employee rosters, bulletin boards, or any other materials or documents designed for public display. Documents, materials, or computer screens that display more than 4 sequential digits of a social security number or other sensitive information shall be kept out of public view at all times, B. Access to Social Security Numbers Only authorized persons shall have access to social security numbers. C. Mailed or Transmitted Documents City documents containing more than 4 sequential digits of a social security number shal! only be sent 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. Documents sent through the mail containing social security numbers shall not reveal the number through the envelope window or otherwise be visible from outside the envelope or package. Social security numbers shall not be sent through email unless the connection is secure or the number is encrypted. No individual shall be required to send more than 4 sequential digits of his or her social security number through email unless the connection is secure or the number is encrypted. D. Public Records Where a social security number is contained within a document subject to FOIA release, the social security number shall be redacted. E. Storage and Disposal All documents or files that contain 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 access. Documents or other materials containing more than 4 sequential digits of a social security number shall not be thrown away in the trash; they shall be discarded or destroyed only in a manner that protects their confidentiality, such as shredding. F. Information Collected Social security numbers should only be collected: 1) to verify an individual’s identity, 2) to investigate an individual’s claim, credit, criminal or driving history, 3) to administer employee benefits, or 4) where required by federal and state law or as otherwise permitted under the Michigan Social Security Number Privacy Act. If a unique identifier is needed, then a substitute for the social security number shall be used where practicable. Whenever the City collects a social security number, it shall inform the individual of the purpose for the collection, the intended use, whether the law requires the number to be provided, and the consequence for not providing the number. G. Accountability Any person who fails to comply with this policy shall be subject to discipline up to and including discharge. Adopted: October 25, 2005 Bon Q. Ksedanges Gail A. Kundinger, City Clerk
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