Policy 3.09

Social Security Numbers

1. Purpose. -- A social security number is considered confidential and exempt from public inspection in accordance with Florida Statutes. The primary purpose of this policy is to ensure that the necessary procedures and awareness exist to ensure that School District employees comply with both the letter and spirit of the Florida Public Records Act, and the Privacy Act of 1974.

2. Policy. -- The School District collects and maintains social security numbers of its employees, students, vendors and others in the ordinary course of its business and as required by law. The School District will handle social security numbers with a high degree of security and confidentiality. In an effort to protect the privacy rights of individuals who provide social security numbers to the School District and to manage its records and records systems responsibly, District employees will:

   1. Ensure the confidentiality of social security numbers in conformance with Florida law;

   2. Not unlawfully disclose, transfer or use an individual's social security number;

   3. Strictly limit access to records and records systems containing social security numbers to those who have a business related reason to know this information; and

   4. When disposing of records with social security numbers, dispose of such records in a responsible manner that minimizes risk that the social security numbers can be accessed inappropriately.

3. Collection from Applicants or Employees.

   1. Social security numbers shall be collected only when allowed by law or when necessary for the performance of the school system's duties.

   2. The School District shall collect the social security number of each applicant and employee for the following purposes:

      1. Verification of citizenship or immigration status, as required by the U. S. Department of Homeland Security or other governmental agencies.

      2. Employee benefit processing, including membership in the Florida Retirement System, health insurance, insurance, or other benefits offered to employees by the School Board.

      3. Compliance with the reporting requirements for the Internal Revenue Service, U. S. Social Security Administration, Unemployment Compensation, Florida Agency for Workforce Innovation, Florida Department of Education and such other official reporting responsibilities imposed by law.

      4. Processing pre-employment and post-employment criminal background checks required by law.

      5. For such purposes as may be directed by the employee, such as direct deposit of wages or salary, payroll deductions, etc.

   3. Social security numbers or federal employer identification numbers shall be collected from all vendors to facilitate vendor record keeping by the School District and to permit compliance with income reporting requirements of the Internal Revenue Service, including but not necessarily limited to issuance of U.S. Internal Revenue Form 1099.

4. Collection from Students. -- Student social security numbers are confidential and will only be released in accordance with the consent requirement set forth in § 1002.22(3)(d), Florida Statutes, or as otherwise provided by that section. Social security numbers may be collected from students under the following circumstances:

   1. As required by § 1008.386, Florida Statutes; or

   2. As otherwise consented to by the student or the student's parent or legal guardian.

5. Collection from Volunteers. -- Social security numbers shall be collected from individuals desiring to serve as volunteers or volunteers in the School District's Volunteers in Public Schools Programs, for the criminal background screening as provided in School Board Policy 2.53, and for persons serving as chaperones on field trips as provided in School Board Policy 2.40.

6. Regulations and Procedures.

   1. Social security numbers will not be:

      1. Publicly displayed;

      2. Used as the primary account number or identifier for an individual, except where existing District records or records systems require such use. Existing records or records systems, when retired, will be replaced with records or records systems that do not require or use social security number as the primary account number or identifier; or

      3. Used, transmitted or stored on records or records systems that are not encrypted or secure. This provision shall be implemented throughout the School District by the Department of Information Technology.

   2. It is the School District's intention to comply with this policy, and with all applicable laws regarding the privacy of social security numbers. Corrective action will be taken in the event of intentional violations of this policy. Such action may include the modification of a process, practice, record or record system to better protect the confidentiality of social security numbers, or, if appropriate, disciplinary action in accordance with the applicable disciplinary policy. Loss or theft of social security numbers from District records or records systems will be promptly reported to the Superintendent or designee for responsive action.

7. Notification.

   1. Applicants for employment and employees shall be notified of the requirement for providing their social security number prior to the time of the completion and submission of the application for employment, the submission of their recommendation(s) for employment to the School District and the purposes for which an applicant/employee's number will be used.

   2. Applicants for the Volunteers in Public Schools Program and chaperones for field trips shall be notified that their social security numbers will be used for background checking purposes as provided in the relevant school board policies.

   3. Students and their parents shall be notified if they will be asked to provide their social security numbers at the time of enrollment; however, students and their parents shall also be notified that a student is not required to provide a social security number as a condition of enrollment or graduation. Further, that student social security numbers will be used for the purposes above stated.

8. Review. -- The Superintendent or designee shall review the collection of social security numbers to ensure that the reasons for collection and the process for collection and maintenance are consistent with Florida laws.

9. Release of Social Security Numbers.

   1. Social security numbers may be disclosed to another agency or governmental entity if disclosure is necessary for the receiving agency or entity to perform its duties and responsibilities. The receiving agency shall be responsible for the securing and protection of the provided information.

   2. Non-student social security numbers may be released to a "commercial entity" engaged in the performance of a "commercial activity" as permitted by § 119.071(5) (a), Florida Statutes. The commercial entity must make a written request for the social security numbers which must be: verified; legally signed by an authorized officer, agent or employee; contain the commercial entity's name, business mailing and location address, and business telephone number; and contain a statement of the specific purposes for which it needs the social security numbers and how the numbers will be used in the performance of a commercial activity.

      1. The School District shall annually report to the Executive Office of the Governor, the President of the Senate and the Speaker of the House by January 31^st of each year the identity of all commercial entities that have requested social security numbers during the preceding calendar year and the specific purpose stated by the commercial entity for each request. If no requests have been received during the preceding calendar year, the District shall report that information.