Employee Manual 2023 - Flipbook - Page 71
The organizations that administer or insure these plans – commercial health benefit plans, health
insurers, health maintenance organizations, pharmacy benefits members – may also collect and
exchange this information, in addition to more specific information concerning medical diagnosis
and treatment. While the City does not generally collect such information, it may do so for quality
assurance, plan maintenance, treatment referral, or payment purposes.
How will the City protect Social Security Numbers and PHI?
The City will restrict access to social security numbers and PHI to only those employees or agents of
the City who need to review the information in order to provide health plan services or benefits, to
assist with payment and claims processing, or to ensure quality control and administration of the
City’s benefit plans. In this regard, the City will train employees with access to Social Security
Numbers and PHI to use or disclose only the minimum information necessary to complete the
service required. Also, the City will implement privacy policies, as may be required by law, designed
to protect against the unlawful use or disclosure of your Social Security Number and PHI.
Unless required or permitted by law, effective January 1, 2006, the following actions regarding the
social security numbers of employees are prohibited:
• Public display of all or more than four sequential digits of the social security number.
• Use of all or more than four sequential digits of the social security number as the primary
account number for an individual.
• Visibly print all or more than four sequential digits of the social security number on any
identification badge or card, membership card, permit or license.
• Require an employee to use or transmit all or more than four sequential digits of their social
security number over the internet or a computer system unless the connection is secure or
the transmission is encrypted.
• Require an employee to use or transmit all or more than four sequential digits of their social
security number to gain access to an internet website, computer system, or network unless
the connection is secure, the transmission is encrypted, or a password or other unique
personal identification number or other authentication device is also required to gain
access.
• Include all or more than four sequential digits of the social security number in or on any
document or information mailed or otherwise sent to an individual if it is visible on or
without manipulation, from outside the envelope or packaging.
• Include all or more than four sequential digits of the social security number in any
document or information mailed to a person unless any of the following apply:
o State or Federal law, rule, regulation or court order or rule authorizes, permits, or
requires that a social security number appear in the document.
o The document is sent as part of an application or enrollment process initiated by the
individual.
o The document is sent to establish, confirm the status of, service, amend or
terminate an account, contract, policy or employee or health insurance benefit or to
confirm the accuracy of a social security number of an individual who has an
account, contract, policy or employee or health insurance benefit.
o The document or information is a public record and is mailed in compliance with the
City of Plymouth Employee manual - Page 71 – March 2023