In a recent post on LinkedIn, a question was asked about If, When and Why B2B creditors such as CMA members request or require Social Security Numbers from credit applicants. (https://www.linkedin.com/grp/post/2412088-6014193760244690945?trk=groups-post-b-title) At the time, I posted two responses in which I posed questions for CMA members in connection with the laws governing the use and the protection of SS numbers.
As I read through the other comments, I saw that several credit managers did routinely ask for them, while others were vehemently opposed to doing so.
Now that some time has gone by, I would like to offer the following additional comments for members who obtain SS numbers from applicant companies:
• Create strong policies and procedures about If, When, Why and Which applicants will be asked to provide their Social Security Number.
• Make sure your attorney has reviewed these policies and procedures and has confirmed that your actions are lawful under applicable federal and state laws.
• Publish these policies and procedures, and then enforce them.
• Create a robust mechanism to ensure there is limited access to customer SS numbers and related information.
• Assign one or a limited number of employees the task of safekeeping and safeguarding SS numbers.
• Be sure there are consequences for employees if policies, procedures or safeguards are ignored for any reason.
• Understand the potential costs of a data breach involving personal information including but not limited to SS numbers.
• Understand the disclosure requirements and the remediation obligations and out-of-pocket costs in the event of a data breach.
• Make sure you have a compelling business reason to obtain SS numbers and consumer credit reports.
Where do you stand on this issue? As always, I welcome your feedback.
Michael C. Dennis is the author of the Encyclopedia of Credit (www.encyclopediaofcredit.com), a free, fast, internet resource for credit and collection professionals. He is a consultant, and the author of “Credit and Collection Forms and Procedures Manual” as well as a frequent instructor at CMA-sponsored educational events. His most recent book, “Happy Customers, Faster Cash,” is available at amazon.com. He can be contacted at 949-584-9685.