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Planning an SSN Compliance Campaign

Checklist for Department Heads & Administrators

Click here for a printable version of this checklist.

Communications

  • Present, or invite a privacy officer to present, the SSN-PII policy and related Data Classification and Record Retention policies at meetings of:
    • department administrators
    • department managers
    • department faculty
    • department staff
  • Announce the availability of secure paper disposal methods
    • shredders
    • locked toters
  • Include SSN-PII disposal in periodic Clean & Go Green days in the department

Discovery

  • Personnel files (including I-9s) in individual offices and in the department office
  • Department-developed forms that currently or have previously required SSN
  • Finance files, e.g. salary administration, older cum salary reports
  • Research files (especially W-9s) in individual offices and in the department office
  • Student records
  • HRMS reports or extracts or screen-prints
  • Contracts with outside parties who are maintaining a data collection for the department
  • Infection case report forms
  • Unemployment insurance forms
  • Faculty file cards and roster databases
  • Archival (dead) storage on-site or at outside location, such as Iron Mountain
  • Department-developed applications and databases (a.k.a. shadow systems)
  • Saved email, both received and sent
  • "Home" directories and department or project file directories on file servers
  • Backup tapes from departmental systems
  • Microfiche, CDs, DVDs, flash ("thumb") drives, external disk drives
  • Ask long-serving employees about past departmental practices that included SSN

Reduction

  • Review the Record Retention policy and dispose of obsolete records (http://www.rochester.edu/adminfinance/records.html)
  • Where possible, remove SSN from records that will be retained
  • Consolidate storage of SSN records, for example, in the department office or a central file server
  • Change department workflow so that copies of SSN are rarely needed
    • Remove SSN from circulating paper files, such as student applications and patient records
    • Minimize emailing or faxing records containing SSN
    • Minimize extracting records containing SSN from central databases and information systems
    • Minimize including fields on paper forms that invite the submitter to provide SSN
    • Minimize including fields on Web sites that invite the submitter to provide SSN

Protection

Electronic

  • Move records containing SSN to a file server in the University Data Center and access them there
  • Encrypt records containing SSN that must be outside the University Data Center. This includes records on Departmental servers:

Paper and microfiche

  •  At the end of the work day, these records containing SSN should be stored in a locked cabinet in a locked room

Disposal

Electronic

  • If the record is stored on a file server in the University Data Center, you may just delete the SSN or the record
  • If the record is encrypted, you may just delete the SSN or the record
  • If the record is stored on write-once media, such as CD-R, you must destroy the media
  • Otherwise you must overwrite the record or destroy the media

Paper and microfiche

  • Shred
  • Securely transfer to an approved secure waste disposal company, for example, via a locked toter for paper disposal

Registration

  • If you still possess a data collection containing SSN, or you are responsible for determining who is permitted to access a data collection containing SSN, register the collection with a Privacy Officer (SSNRegistry@rochester.edu) of the University.
Last modified: April 13, 2009