(A) Purpose.
(1) The Township of Summit (the “township”) is required by the Michigan Social Security Number Privacy Act, Public Act 454 of 2004, being M.C.L.A. §§ 445.81 et seq. (the “Act”), to create a Privacy Policy concerning the social security numbers that it possesses or obtains.
(2) Pursuant to the Act, the Privacy Policy must at least:
(a) Ensure to the extent practicable the confidentiality of the social security numbers;
(b) Prohibit unlawful disclosure of the social security numbers;
(c) Limit who has access to information or documents that contain the social security numbers;
(d) Describe how to properly dispose of documents that contain the social security numbers; and
(e) Establish penalties for violation of the Privacy Policy.
(B) Policy.
(1) 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.
(2) 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.
(C) Procedure.
(1) Obtaining social security numbers.
(a) Social security numbers should be collected only as required by federal and state law, or as permitted by federal and state law, for legitimate reasons in accordance with this privacy policy.
(b) Legitimate reasons include, but are not limited to:
1. Applicants may be required to provide a social security number for purposes of a pre-employment background check;
2. Copies of social security cards may be obtained for purposes of verifying employees’ eligibility for employment;
3. 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; and
4. Social security numbers may be obtained from creditors or vendors for tax reporting purposes.
(2) Public display.
(a) No more than 4 sequential digits of a social security number shall be placed on an identification card, badge, time card, employee roster, bulletin board, permit, license or any other material or document designed for public display.
(b) Any document, material, or computer screen displaying more than 4 sequential digits of a social security number shall be out of public view at all times.
(3) Account numbers. No more than 4 sequential digits of a social security number shall be used as an account number for an individual.
(4) Computer transmission. No more than 4 sequential digits of a social security number shall be used or transmitted via the internet or on a computer system or network unless the connection is secure or the transmission is encrypted.
(5) Mailed documents. Township documents containing more than 4 sequential digits of a social security number shall only be sent in cases where federal or state law, rule, regulation, or court order or rule authorize such. In such cases, the social security number shall not be visible through the envelope.
(6) Freedom of Information Act. When more than 4 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 rendered unreadable before the document or copy of the document is disclosed.
(7) Storage. All documents containing social security numbers shall be stored in a secure manner; social security numbers shall not be stored on computers or other electronic devices that are not secured against unauthorized access.
(8) Access to social security numbers.
(a) Only personnel with legitimate business reasons shall have access to records containing social security numbers.
(b) Department heads with access to records containing social security numbers shall determine which other personnel within their department have a legitimate reason, in the ordinary course of business of the township, to have access to the social security numbers.
(c) Personnel using records containing social security numbers must take appropriate steps to secure the records when not in use.
(9) Disposal.
(a) Documents containing social security numbers will be retained in accordance with the requirements of federal and state laws.
(b) Upon the close of the retention period, documents containing social security numbers must be shredded or otherwise disposed of in a manner that protects the confidentiality of the social security numbers.
(10) Unauthorized use or disclosure of social security numbers.
(a) The township shall take reasonable measures to enforce this Privacy Policy and to correct and prevent the occurrence of violation.
(b) Any employee who knowingly obtains, uses, or discloses social security numbers for unlawful purposes or in violation of this Privacy Policy shall be subject to discipline, up to and including discharge.
(c) Additionally, certain violations of the Act carry criminal and/or civil sanctions.
(d) The township will cooperate with law enforcement and/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.
(Res. passed 11-8-2005)