Appropriate Use of Social Security Numbers at GW

The George Washington University collects and uses individuals’ Social Security Number (SSN) only as permitted or required by law, or when deemed essential, to perform the duties and responsibilities of the University. Where schools and departments are required to request personal information from individuals, generate reports involving personal information, extract personal information from University Enterprise Systems, or otherwise use personally identifying information to accomplish a responsibility, schools and departments must examine their forms, processes and practices to determine whether the use of SSNs is essential or whether use of the GWid and/or some other form or combination of identifying information will suffice. Any collection or use of SSN, for a purpose not outlined in this guidance, should be submitted for review to the GW Privacy Office.

When use of the Social Security Numbers is required, GW schools and departments are responsible for protecting the privacy and confidentiality of SSN information, and preventing the unauthorized or accidental disclosure of SSNs. GW Schools and departments shall comply with university privacy policies and data protection requirements, and implement practices and procedures to protect the confidentiality of SSN data, in any and all formats, including but not limited to oral, paper, electronic, stored media, and electronic transmission.

As general examples, GW may collect and use Social Security Numbers (SSN) for the following purposes:

Appropriate Purpose for Use of SSNs

Tax Reporting	A Social Security Number (SSN) is required as a taxpayer ID for all tax information reported to the Internal Revenue Service, including wage and withholding data for full-time and part-time faculty and students (W-2’s), for honoraria provided to guest lecturers, and for individuals working for the university as independent contractors (1099’s). In addition, an SSN is required as a taxpayer ID when reporting annual tuition received from students to the Internal Revenue Service (1098T’s).
Financial Aid	A Social Security Number (SSN) is necessary to obtain financial information and to identify and confirm the level of financial aid assistance.
Human Resources	The Immigration Reform and Control Act of 1986 (IRCA) requires the use of an SSN for I-9 forms. Certain benefit providers, such as health insurance companies, also may require an SSN for verification of eligibility and coordination of benefits.
Law Enforcement	Federal and state agencies often rely upon SSNs as the primary identifier for law enforcement, and for civil and criminal information purposes. In the event such agencies request SSN information using proper procedures, and the university has such information, it will be provided following review and approval by the Office of the Vice President and General Counsel.