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From:
"Roach, Bill" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 7 Jul 2011 16:51:49 -0500
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>> a guy in the IT group asked my opinion on HR using the last four digits of employee’s social security number to identify their records in Documentum<<

I guess I have a different take on the matter from those who have already commented.  I think the crux of the issue is who is going to have access to the indexes and content in Documentum.  If the materials are going to be accessible across the organization it's a very bad idea. If the indexing and materials are only accessible to HR, I don't see it as a problem.  After all, the materials being secured often include the SSN number of the individual. 

Please note that it I don't believe it should ever be used as the primary ID for employees.  In addition to Murphy's law implications, employee ID's have a tendency to be used for all sorts of things.  Gordy is right, it is not hard to gather a few basic facts and make some very intelligent guesses (think social media...).

I think in some instances, use of the SSN or portion of the SSN for indexing and retrieval purposes may increase information security and privacy protections.  Especially in a large organization where there is potential for multiple individuals having the same name.  I do not want HR staff to inadvertently disclose tax documents, garnishments or other materials to the wrong individual because of a reluctance to use a reliable indexing value.

Finally, I don't recall any laws or regulations that would restrict the use of all or a portion of the SSN as an identifier in HR or related areas (benefits, payroll, etc.).  In many cases, the laws governing reporting require its use.

Bill Roach, CRM

Opinions are my own and not those of my employer or any other organization.

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