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Planning for the Elimination of Social Security Numbers as Primary Identifiers Mike Corn, University of Illinois Jenny Mehmedovic, University of Kansas.

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Presentation on theme: "Planning for the Elimination of Social Security Numbers as Primary Identifiers Mike Corn, University of Illinois Jenny Mehmedovic, University of Kansas."— Presentation transcript:

1 Planning for the Elimination of Social Security Numbers as Primary Identifiers Mike Corn, University of Illinois Jenny Mehmedovic, University of Kansas Sheila Ochner, University of Texas

2 Defining the Problem “The first step to recovery is admitting you have a problem.” SSN Users Anonymous

3 Defining the Problem The Social Security Number Where is it? How is it used? What are the institution’s legal obligations and liabilities in protecting it?

4 Introductory Snapshots Current state of SSN usage at University of Illinois University of Kansas University of Texas

5 Legal Requirements? 1974 The Privacy Act (5 U.S.C. 552A) Family Educational Rights & Privacy Act (FERPA) 1986 Electronic Communications Privacy Act (ECPA) 1996 Health Insurance Portability and Accountability Act (HIPAA) 1999 Gramm-Leach-Bliley Act, “Privacy of Consumer Financial Information” 2001 USA Patriot Act Future Legislation At least 9 pending items

6 Plotting your Approach Tactical? Independent tasks you can undertake to remediate SSN usage Strategic? Comprehensive institutional plan

7 Planning to Start Designate responsibility See what other universities are doing Define the SSN business problem Educate the community Gain support of administration Identify uses/need for SSN Define universe of systems to be examined Create an SSN replacement plan

8 When the Worst Happens Real-life examples of SSN exposure Not recommended! But do highlight the need to identify/use SSN alternatives

9 Next Steps Survey applicable law and resulting legal obligations Assess risk/benefit/viability of SSN removal “What would it cost us in dollars and prestige when a judge orders us into compliance on a very short timescale?” Write policy Implement use of disclosure statements Build a representative body Have a plan for responding to complaints

10 Continuous Improvement Google is your friend – use it to search for SSN in your campus domain! Address new problems as they arise Long-term process Risk-benefit analysis Managing expectations Can’t accomplish EVERYthing FIRST

11 Raising Awareness How to do it? Methods/tools to use? Different audiences – different points Univ. systems v. dep’t systems? Start with deans, directors

12 Lessons Learned Cast the net deep & wide to catch all the distributed systems/uses. Wrap yourself in the law. If you are not in compliance, you must change. In an era where identity theft is the #1 consumer crime, SSN usage needs to be understood as a major privacy concern.

13 Contact Information Mike Jenny Mehmedovic Sheila Ochner


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