TOWNSHIP OF SCIO
WASHTENAW COUNTY, MICHIGAN
SOCIAL SECURITY NUMBER PRIVACY POLICY
1. Purpose.
The Township of Scio (the "Township") 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, this policy sets forth the Township's policies and procedures regarding how Social Security numbers are obtained, stored, transferred, used, disclosed and disposed the privacy policy to:
· Ensure the confidentiality of the Social Security numbers to the extent practicable.
· Prohibit unlawful disclosure of the Social Security numbers.
· Limit who has access to information or documents that contain the Social Security numbers.
· Describe how to properly dispose of documents that contain the Social Security numbers.
· Establish penalties for violation of the privacy policy. .
2. Policy.
It is the policy of the Township to protect the confidentiality of Social Security numbers obtained in the ordinary course of township 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 Township obtains or possesses except in accordance with the Act and this Privacy Policy.
3. Procedure.
a. Obtaining Social Security Numbers. 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.
Legitimate reasons for collecting a Social Security number include, but are not limited to:
· Applicants may be required to provide a Social Security number for purposes of a pre-employment background check.
· Copies of Social Security cards may be obtained for purposes of verifying employee eligibility for employment.
· Social Security numbers may be obtained from employees for tax reporting purposes, for new hire reporting or for purposes of enrollment in any Township employee benefit plans.
· Social Security numbers may be obtained from creditors or vendors for tax reporting purposes.
b. Public Display. All or more than four sequential digits of a Social Security number shall not be placed on identification cards, badges, time cards, employee rosters, bulletin boards, permits, licenses or any other materials or documents designed for public display. Documents, materials or computer screens that display all or more than four sequential digits of a Social Security number shall be kept out of public view at all times.
c. Account Numbers. All or more than four sequential digits of a Social Security number shall not be used as a primary account number for an individual.
d. Computer Transmission. All or more than four sequential digits of a Social Security number shall not be used or transmitted on the Internet or on a computer system or network unless the connection is secure or the transmission is encrypted.
e. Mailed Documents. Township documents containing all or more than four sequential digits of a Social Security number shall 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 containing all or more than four sequential digits of a Social Security number, that are sent through the mail, shall not reveal the number through the envelope window or otherwise be visible from outside the envelope or package.
f. Freedom of Information Act. Where all or 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 a document is disclosed.
g. Storage. 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 access.
h. Access to Social Security Numbers. Only personnel who have legitimate business reasons to know will have access to records containing Social Security numbers. The department heads having access to records containing Social Security numbers shall determine which other personnel within their departments have a legitimate reason in the Township's ordinary course of business to have access to such Social Security numbers. Personnel using records containing Social Security numbers must take appropriate steps to secure such records when not in immediate use.
i. Disposal. Documents containing Social Security numbers will be retained in accordance with the requirements of state and federal laws. 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 shredding.
4. Unauthorized Use or Disclosure of Social Security Numbers.
The Township shall take reasonable measures to enforce this Privacy Policy and to correct and prevent the reoccurrence of any known violations. Any employee, who knowingly obtains, uses or discloses Social Security numbers for unlawful purposes or contrary to the requirements of this privacy policy shall be subject to discipline up to and including discharge. Additionally, certain violations of the Act carry criminal and/or civil sanctions. The Township will cooperate with appropriate law enforcement or administrative agencies in the apprehension and prosecution of any person who knowingly obtains, uses or discloses Social Security numbers through the Township for unlawful purposes.
TOWNSHIP OF SCIO,
WASHTENAW COUNTY, MICHIGAN
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Charles D. Supervisor
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Kathleen P. Knol, Clerk
CERTIFICATION:
I, Kathleen P. Knol, Clerk of the Township of Scio, County of Washtenaw, Michigan, do hereby certify that the foregoing is a true and complete copy of a resolution approved by the Board of Trustees on the ___th day of ________, 2006. The following members of the Scio Township Board of Trustees voted as follows in connection with this resolution.
AYES:
NAYS:
ABSENT:
In witness hereof, I have hereunto affixed my official seal this ___th day of _________________, 2006.
__________________________________
Kathleen P. Knol, Clerk,
Township of Scio
