SOCIAL SECURITY NUMBER (SSN) PRIVACY POLICY

PURPOSE:
The Benton Harbor Area School District is required by the Michigan Social Security Number Privacy Act, Public Act 454 of 2004, MCL 445.81 et seq., (the “Act”) to create a privacy policy concerning the social security numbers that it possesses or obtains.

Pursuant to the Act, the privacy policy must at least:

1. Ensure to the extent practicable the confidentiality of the social security numbers.
2. Prohibit unlawful disclosure of the social security numbers.
3. Limit who has access to information of documents that contain the social security numbers.
4. Describe how to properly disposes of documents that contain the social security numbers.
5. Establish penalties for violation of the privacy policy.

This privacy policy sets forth the District’s policies and procedures regarding how social security numbers are obtained, stored, transferred, used, disclosed and disposed.

POLICY:
 It is the policy of the District to protect the confidentiality of social security numbers obtained in the ordinary course of District business from employees, vendors, contractors, customers or others.  No person shall knowingly obtain, store, transfer, use, disclose, or dispose of a social security number that the District obtains or possesses except in accordance with the Act and this privacy policy.

PROCEDURE:
Social security numbers should be collected only where required by federal and state law or as otherwise permitted by federal and state law for legitimate reasons consistent with this privacy policy.

The number of individuals having access to the SSNs will be restricted to persons authorized to work with these records.  These individuals will sign a confidentiality agreement.  The Superintendent or designee will determine the authorized person(s).

Documents containing SSNs shall be kept in confidential files.  Except as required by necessary and legitimate purposes, no employee is permitted to have access to SSNs (including documents that contain any SSNs) or to keep, view, use, copy, disclose, or distribute another person’s SSN, or in any other way disclose another’s SSN.  One who accesses a SSN for necessary and legitimate purposes is prohibited from using or accessing the SSN in a manner that may permit an unauthorized individual to view, use, or access the number.

When documents containing SSNs are no longer needed and are to be discarded, such documents must be disposed of in a manner that ensures the confidentiality of the SSNs.  The District has developed a practice for shredding, electronically deleting, or otherwise disposing of confidential records, including documents containing SSNs.