Michigan law requires employers collecting Social Security numbers to implement Privacy Policy.

Release date: January 01, 2006  /  Print This      

In early 2005, Michigan became the first state in the nation to enact legislation requiring that every employer maintain a policy safeguarding the privacy of employee social security numbers collected by the employer. The deadline for implementation was January 1, 2006. Such policies must do, at least, the following:

· Ensure to the extent practicable the confidentiality of social security numbers.

· Prohibit unlawful disclosure of social security numbers.

· Limit who has access to information or documents that contain social security numbers.

· Describe how to properly dispose of documents that contain social security numbers.

· Establish penalties for violation of the privacy policy.

Employers must include the new privacy policies in employee handbooks, procedure manuals or similar documents.

The new law also contains a number of specific safeguards regarding the use and display of social security numbers maintained by employers. For example, the use of more than four sequential digits of an individual’s social security number is restricted in any public display over the internet, a computer or network; as a primary account number on any identification badge, membership card, permit or license; or in mailed documents if the number is visible from the outside of the envelope or package.

Contact one of the firm’s labor and employment attorneys for an appropriate privacy policy.