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I concur with comments made that you should check with state laws -- or
states' laws if your utility operates in more than one state -- relative
to the use of portions of a SSN.

My personal reaction, though, is "why?"  There are better alternatives.
Why get your employees all riled up?  (And they will NOT be happy with
this policy.)  Stirring up the masses.  Bad PR move.  Period.

With that said, the 4-digit, SSN data collection practice is in use for
voter registration purposes in 43 states.  The Help America Vote Act
requires states to verify the identity of registered voters.  If the
individual does not produce a driver's license, the last four digits of
the Social Security number may be collected which can then be used by
the state to verify identity with the Social Security Administration
using those four digits, the individual's birthdate, and his/her name to
cross check the information against the Social Security Administrations'
database  (http://www.socialsecurity.gov/open/havv/#statesNotUsing).

The information is captured on the individual's voter registration card,
which is public information in most of those 43 states (which is rather
scary given that the voter registration card also includes birthdate and
other personal information).

I did work for a company some years ago (17) that used the last four
digits of the employee's SSN for an employee ID number.  The company
would add a fifth number to the string-of-four in case there was more
than one individual with the same SSN numbers, e.g. 99991, 99992, 99993.

So...the federal government permits the practice for voter registration.
It has been done in the corporate world in the past.  But trust your
gut. Discourage the practice.  HR might get the system in place, then
your state might ban the use of partial SSNs in a year or two, and HR
will have to re-create their system at some expense of time and money.

Paul Bergeron, CA, CMC
City Clerk
229 Main Street
Nashua, NH  03060


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Laura Boldt
Sent: Thursday, July 07, 2011 4:06 PM
To: [log in to unmask]
Subject: [RM] Using the last 4 digits of an employees SS number

I work for a large utility company and a guy in the IT group asked my
opinion on HR using the last four digits of employee's social security
number to identify their records in Documentum.  HR records are not my
area of expertise but my gut reaction is that they should use another
indentifying number.  

First question, am I off base in my gut reaction?  If I'm not, is there
any standard, guideline, etc. that I can point them to for reference?

Thanks,

Laura Boldt CRM
[log in to unmask]

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