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A Better Partnership


Feb 2006
February 01, 2006

State Passes Social Security Number Privacy Law

The State of Michigan recently passed a law which will likely impact every employer with operations in the State. Public Act 454 of 2004 requires anyone who obtains a social security number in the ordinary course of business to create and publish a privacy policy governing the use and disclosure of those numbers. Since virtually every employer obtains employee social security numbers for payroll, benefit enrollment, tax-reporting and employment eligibility purposes, this new law will have widespread impact.

The privacy policy required by Act 454 must:

  • ensure the confidentiality of the social security numbers;
  • prohibit the unlawful disclosure of social security numbers;
  • limit access to documents containing social security numbers;
  • establish procedures for disposal of documents containing social security numbers; and
  • prescribe penalties for violation of the privacy policy.

Anyone who develops a privacy policy must publish the policy in an employee handbook, a procedure manual, or in similar document. The policy may be made available electronically.

Although the law takes effect March 1, 2005, employers and others have until January 1, 2006 to develop and publish their privacy policies.

For more information, please contact Rob Dubault at or by phone at 231.772.2638.

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