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Report Issued on The Use of Social Security Numbers in California Colleges and Universities

On July 1, 2010, the California College and University Social Security Number Task Force, established by the Office of Privacy Protection, issued a report, “The Use of Social Security Numbers in California Colleges and Universities”. The two main recommendations are reviewing your institution's practices on Social Security numbers (SSNs) and establishing institutional data governance programs. Several appendices cover legislative efforts to control SSNs, data breaches in higher education, a survey questionnaire, and best practice references from several institutions. The report is available to download for free. Please note: These findings and recommendations are for informational purposes. As stated in the report on page 17,"each institution must evaluate the recommendations for their applicability to its present circumstances, including prioritization, being mindful that they are not intended to be prescriptive nor a recipe for a comprehensive data governance program.”

The first step towards safeguarding SSNs is the minimization principle: to collect only those SSNs that are necessary, protect what is collected and retain it only as long as necessary. While this should remain a guiding principle, the reality is more complex. Most SSNs that are collected are required externally either by legislation or operational requirements. In addition, SSNs must sometimes be retained beyond what would appear to be necessary at first glance.The [task force] recognizes the great diversity of environments of higher education institutions and thus offers these recommendations with the hope and expectation that institutions will find them helpful in identifying actions that could enhance their privacy programs.

  1. Review practices on Social Security numbers.

    • Eliminate the unnecessary collection of SSNs.
    • Protect SSNs that must be stored.
    • Retain SSNs for the shortest time necessary.
  2. Establish institutional data governance programs.

    • Develop and implement a campus privacy program to include ongoing education and awareness.
    • Continue to improve data protection in patient care settings.
    • Under-resourced community colleges should enhance their data governance programs, seeking out resources from EDUCAUSE and opportunities to collaborate locally with other public systems.
    • Enhance online privacy practices, starting with institutional web sites.