UC Santa Barbara                                      Policy 7010
   Policies                                              
   Issuing Unit:  Administrative Services                Date: October 1, 1985
   
   
   
   
           COLLECTION AND USE OF SOCIAL SECURITY NUMBER
   
   I.   REFERENCES:
   
        A.   Federal Privacy Act of 1975 (Public Law 93-579), as amended.
        
        B.   President Saxon's memo to Chancellors, December 10, 1976,
             regarding Privacy Act.
   
   II.  POLICY:
   
        The Federal Privacy Act is designed to safeguard the rights and
        privacy of individuals from the encroachments of Federal agencies in
        maintaining records on individuals. The Act serves to guarantee to
        individual citizens that the Federal government will not release
        information about them to the general public if that information
        could in any way constitute a clearly unwarranted invasion of
        personal privacy. It applies to the University with respect to
        collection and use of the Social Security Number and in the
        relatively few instances when the University enters into a contract
        (not a grant) with a Federal agency and in which the University
        agrees to undertake the design, development, or operation of a
        system of records on individuals which accomplishes a function of
        the Federal sponsoring agency.
   
        A.   Collection:
        
             In all instances, when the University requests an individual to
             supply his/her Social Security Number, it must indicate in
             writing (1) whether disclosure is mandatory or voluntary, (2)
             by what authority the number is requested, and (3) the uses
             which will be made of it. See Attachment A for sample notices
             concerning collection of the Social Security Number; all forms
             used to collect the Social Security Number must contain one of
             these statements.
        
        B.   Mandatory versus Voluntary:
        
             1.   In cases of mandatory disclosure, documentation should be
                  on file which included dated correspondence or copies of
                  dated forms demonstrating: (a) that the disclosure
                  requirement is mandatory; (b) that the record-keeping
                  system was established prior to January 1, 1975; (c) that
                  no substantial changes in such systems have taken place
                  since that time; and (d) that the use or uses the number
                  is put to remain substantially unchanged. In general, if
                  these conditions cannot be met, disclosure of the Social
                  Security Number must be on a voluntary basis.
             
             2.   The University may not deny to any individual any right,
                  benefit, or privilege provided by law because of that
                  individual's refusal to disclose his/her Social Security
                  Number, unless:
        
                  a.   The disclosure is required by law (as in the case of
                       forms used to record income and withholding e.g.,
                       Form W-4, Employee's Federal-State Withholding
                       Allowance Certificate), or
                  
                  b.   The University system of records which requires the
                       Social Security Number was in existence and operating
                       before January 1, 1975, the disclosure is required by
                       law or University procedure in effect prior to that
                       date, and in order to verify the identity of an
                       individual.
        
        C.   New Record Systems:
        
             A new University record system (i.e., exclusive of State or
             Federal law requirements) may be established using the Social
             Security Number as an identifier only, if at collection, the
             individual is notified that disclosure is voluntary.
        
        D.   Employee ID Number versus Social Security Number:
        
             The use of the Social Security Number as an employee identifier
             is limited to payroll purposes, unless the filing system was in
             place prior to January 1, 1985. An employee's identification
             number for non-payroll purposes is the six-digit number found
             in the lower left of their PAF form (MPP=).
   
   
   III. ATTACHMENT:
   
        A.   Sample Notices for Collection of the Social Security Number.
   



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Last Modified By: EBH, 7/09/98