SSNs on benefit statements

[pcbenefits007]

Anyone aware of a requirement to use only the last 4 numbers of a participant's SSN on statement and if so where that requirement is? Coming up w/ nothing so far so maybe there is no requirement to do so, but rather a best practice?

[david rigby]

In these days of concern for personal security, why would anyone want to use the full SSN?

As an example, IRC 414(p) defines the information required in a QDRO, including the mailing address of the alternate payee. This is a public document, so including mailing address might be a very bad thing in the case of domestic violence, or including SSN makes that available to the world. Therefore, everyone now understands that certain information can (should) omitted from public documents for privacy/security reasons. Now, extend this principle to your question.

IMHO, best practice will avoid using the full SSN on a statement.

[pcbenefits007]

No argument to use the full SSN but searching for any official guidance that says you have to use the last 4 of the SSN. Yes, its a best practice, but thinking there's nothing prescribing the last 4.

Thanks for the feedback.

In these days of concern for personal security, why would anyone want to use the full SSN?

As an example, IRC 414(p) defines the information required in a QDRO, including the mailing address of the alternate payee. This is a public document, so including mailing address might be a very bad thing in the case of domestic violence, or including SSN makes that available to the world. Therefore, everyone now understands that certain information can (should) omitted from public documents for privacy/security reasons. Now, extend this principle to your question.

IMHO, best practice will avoid using the full SSN on a statement.

[BG5150]

I believe in some states, you aren't allowed to put stuff in the mail with SSNs on it.

[BG5150]

The reason for the last 4 digits is that it's less probably that someone with the same or similar name will have the same last 4 digits.

[PensionPro]

Under California Civil Code Section 1798.85-1798.89 companies may not publicly display or post SSNs or mail anything to customers containing SSNs.

Here is the state statute that permits use of the last four digits in certain instances: "Unless otherwise required to do so by state or federal law, no person, entity, or governmental agency shall present for recording or filing with a county recorder a document that is required by any provision of law to be open to the public if that record displays more than the last four digits of a social security number. Unless otherwise authorized by state or federal law, a document containing more than the last four digits of a social security number is not entitled for recording."

[masteff]

What BG said. Edit: the following is from an education related website but gives you a good idea of state SSN law: http://www.dataqualitycampaign.org/files/SSN%20protection%20laws_CHART_02%2021%20for%20posting.pdf

In really big companies, you start having people with same names, so an ID number is helpful to distinguish. But really big companies have already switched to their own unique ID numbers and put those on statements in lieu of SSN.