The statute dictates that we may no longer use the SSN as the assigned identifier after June 30, 2002. These uses must be consistent with applicable privacy law. The first sentence of paragraph A essentially calls for a technical solution. Other broad access to the number, including its use as a primary access key even if the number is not on the face of an identification card, is likely contrary to the basic need to know structure of federal privacy regulations. The second sentence of paragraph A regarding posting of numbers is less technical and requires a training solution.
Advisors regularly have sign-up sheets on open counters.
This practice, regardless how poorly-advised in the past, is no longer arguably legal as of June 30, 2002. Faculty are regularly advised not to post grades by SSN, and the training must be broadened to advise them that they may not use portions of the number. The above conclusions are somewhat complicated by the paragraph B requirement of an SSN ID option. Despite the fact that the SSN should not be used as a primary search key, and that screens should not reveal SSNs to individuals other than those preparing federal reports absent a statutory change, we will need to engineer our systems to be searchable by an available and disclosed SSN to accommodate the requirement that individuals be allowed to use the SSN as their identification number. This is accomplished through searchability of the databases by SSN in the event an individual provides the number verbally or in writing.