Secure Use of SSNs by Private Entities, Including NABP

May 19, 2011 8:57 AM

As pharmacists and pharmacy technicians create their NABP e-Profiles to obtain their e-Profile ID for use in the CPE Monitor service, some have asked for clarification regarding the use of Social Security numbers (SSNs) in the profile information.

Although some may believe that non-governmental organizations are prohibited from obtaining SSNs, in fact there is no law banning private organizations from collecting SSNs. In recent years, a federal government task force recognized the importance of SSN use by private entities and preservation of such use. For example, individuals and organizations such as landlords, health insurers, and banks acquire SSNs for a variety of reasons ranging from credit checking to identity verification to government compliance.

Many states’ laws specifically permit private entities to collect and use individual SSNs for purposes of application and enrollment processes, to confirm SSN accuracy, or for internal verification or administrative purposes. Moreover, federal law mandates the collection of SSNs, pursuant to licensure processes, under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. Accordingly, the states have incorporated this federal requirement into their laws. Two examples are Illinois and Oregon: both codified the federal requirement into pharmacy practice laws requiring individuals to provide SSNs for license issuance and renewal purposes.

Myriad laws require government agencies and private entities to provide protections for SSNs. For example, most states require private entities to implement encryption technologies so that individuals can securely submit SSNs online. As a private entity that for many decades has supported the boards of pharmacy in their licensure processes, NABP utilizes required technologies and protections, and adheres to state and federal laws when collecting SSNs for purposes of internal data verification and board of pharmacy licensure processes.