Penn State - Administrative
This policy governs the use of Social Security numbers (SSN) at Penn State and recognizes the use of the PSU ID as the primary identification number for students and employees. Any personal health information originating from a covered component of Penn State and attached to the SSN may be protected health information (see Policy AD22). The Pennsylvania College of Technology, although affiliated with Penn State, has its own policy regarding the use of SSNs within its systems. However, its policy must provide compatibility with ISIS (Integrated Student Information System) and IBIS (Integrated Business Information System) as necessary.
Penn State is committed to maintaining the privacy and confidentiality of an individual's SSN. Therefore, the use of SSNs as an identification number within the University shall be limited. A Penn State Identification Number (PSU ID) is assigned to all students and employees of Penn State as the primary identification number for Penn State purposes. SSNs will only be requested and required in certain cases, such as when required by law or for business purposes with certain third party providers, with appropriate disclosure of its use, and then stored as a private data element in Penn State's Central ID Repository (CIDR).
The University's Chief Privacy Officer will have oversight of the policy issues related to the PSU ID as well as the collection of the SSN within University systems. Federal and state regulations, such as the Family Educational Rights and Privacy Act of 1974 (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA), will be monitored by the Chief Privacy Officer to assure Penn State policies are in compliance.
COLLECTION OF SOCIAL SECURITY NUMBER WITHIN UNIVERSITY RECORDS:
The SSN will be required to be collected and recorded when needed by federal or state governmental agencies or by outside third parties. Other reasons for collecting a SSN may be designated by the Office of General Counsel or the University Chief Privacy Officer.
Authorized University employees may use SSNs during the execution of their duties, especially if a primary means of identification, such as the PSU ID, is not known or available.
University offices may not collect SSNs for other purposes, except those noted below. Even these areas must request an authorization from the Chief Privacy Officer if the SSN is to be stored electronically anywhere other than Penn State's Central ID Repository (CIDR). The primary uses and reasons for collecting a SSN include the following:
- Enrollment: Those wishing to enroll in academic offerings at Penn State - both credit and non-credit - are required to provide a SSN for secondary identification purposes. IRS regulations do require the University to request a SSN as a Taxpayer ID number for use in tax reporting. In addition, any student applying for Financial Aid must provide a SSN to the University.
If a person enrolling in a Penn State academic offering - credit or non-credit - refuses to provide a SSN, certain services, such as transcripts, enrollment verification, tax reporting, financial aid and other services may not be available to the individual, and Penn State cannot guarantee a complete academic record for the individual.
- Immigration Law: A SSN must be provided on I-9's in accordance with the Immigration and Control Act of 1986 (IRCA), as overseen by OHR International Scholars and Faculty Visa Services (ISFVS). SSN collection is required to meet INS regulations for international students under the purview of the Office of International Students.
- Certification Exams/Cooperative Experiences/Internships: A SSN is required to be collected and reported for students who are taking certification exams if mandated by the certifying agency. Employers participating in co-ops and internships may also require the student to provide a SSN.
- Employment: Any person employed by the University must provide a SSN as the taxpayer ID number as directed by the IRS. This includes all employees, including part-time and student employees. Providing the SSN is a condition of employment. Applicants for employment must also provide a SSN, if requested, for mandatory background checks.
- Employee Benefits: If required by a benefits provider, the SSNs of dependents may be collected to receive service. Penn State may also release an employee's SSN to benefit providers.
- Payment for Personal or Professional Services: Any person providing services to the University as a independent contractor, invited speaker (honorarium) or research subject for which payment will be made, must provide a SSN as the taxpayer ID number per IRS regulations. These taxpayer ID numbers will be stored in the accounts payable system as part of the vendor record.
- Planned Giving Donors: Donors participating in planned giving programs must provide a SSN as the taxpayer ID per IRS regulations.
- Police Services: Because the SSN is, and will continue to be, a primary identifier for law enforcement and criminal justice records, Police Services has access to the SSN information in all systems. Suspects and defendants will be asked for their SSN because this is used as a personal identifier in criminal justice databases (e.g. FBI NCIC, criminal history records, etc.), on citation forms, on criminal complaints, and in local police databases.
The SSN may also be released to entities outside the University where required by federal or state law, regulation or procedure, or if the individual grants permission.
The use of a disclosure statement when requesting the SSN is not required although several University offices have adopted the use of standard disclosure statements on forms requesting SSNs from prospective students and on forms where services are requested that require SSNs.
SECURITY AND PRIVACY OF SOCIAL SECURITY NUMBER:
If a SSN is collected for a student, employee, or other constituent, it will be stored as a private data element for that individual within the Central Identification Repository (CIDR) (with the exception of SSNs collected as taxpayer IDs within the IBIS accounts payable system, which will be stored as part of the vendor record). The University will take reasonable precautions to protect the SSN for all individuals who provide it, but the SSN must be available to University employees if required to complete the business of the University. In no case will a SSN be used as an identifier in a University system covered under this policy, including as an indexing system for imaged documents, unless the Chief Privacy Officer has approved an authorization.
All records containing SSNs, whether on or off-line, will be considered confidential information and should be secured appropriately. If and when these records are no longer needed, disposal of the records must be done securely, and the disposer must follow University Policy AD35 - Archives and Records Management.
CENTRAL IDENTIFICATION REPOSITORY (CIDR):
SSNs are secured in a Central Identification Repository (CIDR) with limited and encrypted (secure) access rights. Those offices which require the storage of SSNs within their systems rather than in CIDR must have permission from the University's Chief Privacy Officer to store the SSN outside CIDR. Crosswalk files that cross-reference PSU IDs to SSNs are prohibited with the exception of CIDR, unless approved by the Chief Privacy Officer. Authorization requests can be made at email@example.com.
The data within CIDR is Penn State data and will be available to those authorized to view data within CIDR. However, the data is considered to be confidential data and may not be used by any office for purposes of data mining.
In certain cases, collection of an individual's SSN may have additional privacy considerations (e.g. the information collected may only be used within the scope of the project for which it was collected) - those cases will be reviewed with the Chief Privacy Officer to determine appropriate handling.
The Corporate Controller's Office has assigned Data Stewards who are responsible for the control of PSU IDs, SSNs and other data elements in the Central Identification Repository (CIDR), including determining which data elements are mandatory and optional for each affiliation. These Data Stewards also coordinate the operational aspects of revising, deleting and merging records within the CIDR, and the issuance of new PSU IDs as required. The Data Stewards will grant permission to appropriate offices to assign the PSU ID. The Data Stewards work closely with the Chief Privacy Officer to implement new policy or procedures intended to protect the confidentiality of individual records and data.
SSN WITHIN HISTORICAL RECORDS:
SSNs may be a part of historical databases or imaged documents given its past use as the primary identifier at Penn State. Penn State will make a good faith effort to convert on-line databases and information, but given the volume of data, will not be able to convert historical records stored in off-line technology or as imaged documents. In no case can SSNs be used as a primary identifier in a University system, including as an indexing system for imaged documents unless the Chief Privacy Officer grants permission. If permission is not granted, the indexes must be changed to use the PSU ID or another key, or the documents must be purged from the system. Following are additional guidelines on use of SSNs within historical records:
- Access to imaged or other on-line documents containing SSNs will be limited and secured through pass-phrase or password.
- Local departmental databases or spreadsheets containing SSNs, which are available through local servers or PCs, are not permitted unless the Chief Privacy Officer grants an authorization.
If faculty or others have email or other electronic correspondence that contains a SSN in the text, this will be considered historical information and does not have to be converted, but must be handled as confidentially as possible, and purged if no longer required.
- Historical records containing SSNs in off-line storage, such as paper, tape, cartridge, fiche, microfilm or magnetic media may be maintained, but access to these off-line records must be limited and secure.
All records that are no longer needed must be purged and disposal of the records must follow University Policy AD35 - Archives and Records Management.
A Penn State Identification Number or PSU ID is assigned to individuals and is to be used as the primary identifier in Penn State's administrative and academic systems. The PSU ID is a nine digit number, beginning with 9 in the following format: 9-XXXX-XXXX.
The PSU ID is unique to the individual and is a lifetime assignment used for multiple and changing relationships with Penn State.
The following apply to all individuals assigned a PSU ID:
- The PSU ID is assigned to an individual and is used for all affiliations with Penn State. Efforts must be made to prevent assignment of multiple PSU IDs to the same individual.
- The PSU ID for an individual will not be available to the general public, such as through the Penn State Directory.
- The PSU ID may only be used in email or other correspondence within the University among appropriate University personnel and offices in performing their assigned duties, or in email or other correspondence sent directly to that individual. The PSU ID should never be part of the subject line of an email or printed on the address label of written correspondence, and unless the full number is required (i.e. to notify an individual of his or her PSU ID), only the last four digits should be used in the text of the email or correspondence.
ASSIGNMENT OF THE PSU ID:
There are three major groups to whom PSU IDs are assigned - students, employees and other entities - and different regulations apply to each.
- Students: A PSU ID is issued to anyone enrolling in Penn State academic offerings - including credit and non-credit instruction - that are recorded in the Integrated Student Information System (ISIS). The PSU ID is the identifier for individuals within Penn State academic systems and will be available to appropriate University officials with a legitimate educational need for the records. Students will be required to provide the PSU ID when requested to obtain access to services at Penn State.
NOTE: Under interpretations of Family Educational Rights and Privacy Act of 1974 (FERPA) regulations, the PSU ID cannot be used to display a student's scores or grades publicly. This also precludes posting grades using only the last four digits of the PSU ID.
- Employees: All Penn State employees, including wage payroll, are issued a PSU ID at the time of employment. The PSU ID will be used to identify the individual within the Integrated Business Information System and other administrative systems. Penn State retirees will also be assigned PSU IDs under this affiliation.
- Other Entities: There are other constituents associated with Penn State who may be issued a PSU ID. These include, but are not limited to, alumni, donors, and "friends of Penn State". The Data Stewards will determine when a PSU ID may be issued for those falling into the "other entity" category.
INITIAL ASSIGNMENT OF THE PSU ID:
Only after determining that an individual does not have a PSU ID will one be assigned. The Data Stewards authorize which areas of the University will have the authority to establish a PSU ID for an individual, if one does not already exist. Assigning a PSU ID will require certain minimum information about the individual as prescribed by the Data Steward. Those offices assigning PSU IDs must notify constituents of their new PSU ID in a timely manner, using consistent methods and wording as specified by the Data Stewards.
DUPLICATE OR MULTIPLE PSU ID:
If multiple PSU IDs are issued to a single individual or if two individuals are issued the same PSU ID, the University office discovering the duplicate or multiple must contact the Data Stewards and after verification of the multiple assignment, the records will be merged or separated and the individual or individuals notified of which PSU ID will be valid in the future.
REPLACEMENT OF PSU ID:
If an assigned PSU ID has been compromised and used fraudulently, an individual may request a new PSU ID number subject to the review and approval of the Chief Privacy Officer.
PSU ID AND PENN STATE id+ CARD:
The PSU ID is printed on the Penn State id+ card so that individuals have a permanent record of their PSU ID for reference purposes. Individuals issued id+ cards will be expected to keep the card secure. The id+ Card has a brief disclosure statement on the back of the card regarding the individual's responsibility for keeping the card and the PSU ID secure: If an id+ card must be replaced, the PSU ID will remain the same, but a new id+ card number will be issued.
Policy AD24 governs the issuance of id+ cards, and not all individuals assigned a PSU ID will receive an id+ card.
Other Policies in this manual should also be referenced, especially the following:
AD11 - University Policy on Confidentiality of Student Records
AD22 - Health Insurance Portability and Accountability Act (HIPAA)
AD24 - Identification Cards
AD35 - Archives and Records Management
Additionally consult this student policy:
Student Policy N-1 - Confidentiality of Student Records
Effective Date: April 11, 2007
Date Approved: April 9, 2007
Date Published: April 10, 2007 (Editorial changes, October 2, 2012)
Most recent changes:
Revision History (and effective dates):