Am I a custodian?

You are not a custodian of Social Security Numbers if your only involvement with other people’s SSNs is when you …

… are a user of computer systems whose access controls are administered by others;
… are a user of paper files or microfiche that are returned at the end of the workday to a secure storage area whose access controls are administered by others.

You might be a custodian of SSNs if …

… you have copies of

performance evaluations,
job applications and resumes,
personnel action forms,
enrollment applications and transcripts,
FRS reports (e.g. cum salary),
travel & conference expense reports,
Requests for Payment,
research databases,
extracts from clinical systems,
curricula vitae (CVs),
financial aid applications,
grant proposals, and
similar documents created at a time when SSN was routinely used as a primary identifier

Or if you …

… are the administrator of a computer

software application that controls access to data that include SSN;
file server directory (e.g. "file share") that includes files or databases containing SSN;
SharePoint site that includes files or lists containing SSN;

… are the administrator of a department or unit or off-campus medical practice that

tracks performance ratings, salary programs, credentials for teacher certification, etc., in computer files stored on a departmental computer or on a file server at a University data center;
oversees student admissions and/or financial aid processes;
keeps paper-based personnel files, including forms such as I-9 and W-9, on your faculty, staff, student employees, and contractors;
keeps paper-based patient files;

… are the investigator or coordinator of a research project that