Use and Management of Social Security Number Policy

PONCE HEALTH SCIENCES UNIVERSITY (PHSU) is committed to maintaining the privacy and confidentiality of Social Security numbers (SSNs). PHSU is cognizant of the risk the improper disclosure of SSNs can have on individuals who have entrusted the information to PHSU, including the risk of identity theft. The collection, management and display of SSNs be controlled and the use of an SSN as an identification number is limited. An SSN may not be used as a primary identifier in a university system and never be used on any public list.

• SSNs may only be requested in certain cases, such as when required by law or for business purposes with certain third-party providers, with appropriate disclosure of their use.
• Online and off-line systems that maintain SSN data must have adequate security controls implemented to protect its confidentiality and integrity.
• PHSU Primary ID (“UPI”) number will serve as the primary identification number for university students, faculty, and staff. A UPI is assigned to all persons affiliated with the University and is displayed on the University’s ID Card.

Violations of this policy are to be reported to the University’s Compliance Officer.

Scope

This policy sets forth the framework for PHSU’S collection, management, and use of Social Security numbers (SSN) and is applicable to all PHSU units.

• This policy will not apply to clinical and patient systems maintained by PHSU that are required to use the SSN for billing and healthcare coordination purposes.
• SSNs are considered an identifier under the Health Insurance Portability and Accountability Act (HIPAA).