Should a Credit Manager Request Personal Social Security Numbers?, by Michael C. Dennis

Michael C. Dennis

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.

2 Replies to “Should a Credit Manager Request Personal Social Security Numbers?, by Michael C. Dennis”

  1. Would you then suggest that we remove the SS line from our credit app and just ask for federal tax ID number?

  2. Doing so would certainly be the easiest and fastest way to manage this risk.

    I want to be clear: I am not suggesting that B2B creditor companies should NOT or should NEVER request SS numbers or purchase consumer credit reports.

    This blog is about understanding that consumer credit reports and SS numbers are governed by various regulations and laws which need to be fully understood and scrupulously followed.

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