Re: Disclosure of SSN

[John Pickering <johnjp@email.sjsu.edu>]

I have not encountered the same problem, however I have come accross a
problem of visiting researchers who had no SSN.  I also had to deal with
monitoring individuals outside the US via a program established within the
use such as for a corporation managed within the US and had radiation
workers in other countries performing the work there.  How we dealt with the
situation was to assign a new number using a letter to make it unique.  Then
we would explore all of the other aspects (legal) which we had to resolve.
This gave us the time for the exploration by our legal department and
allowed us to issue monitors and continue the program.  The researcher was
unable to voice a complaint from the health physics group.
John Pickering
San Jose State University

 At 06:35 PM 8/28/97 -0500, you wrote:
>REGARDING                Disclosure of SSN
>
>I have an individual associated with my facility who has refused to =
>provide his SSN for dosimetry records citing the Privacy Act as his =
>reason -- "Section 7 of Pub L. 93-579 (a)(1) It shall be unlawful for any =
>Federal, State or local government agency to deny to any individual any =
>right, benefit, or privilege provided by law because of such individual's =
>refusal to disclose his social security number."  He also has stated that =
>by denying him dosimetry service, I am in violation of the law.  I =
>countered his argument with section (a)(2)(B) which states "the =
>disclosure of a social security number to any Federal, State or local =
>agency maintaining a system of records in existence and operating before =
>January 1, 1975, if such disclosure was required under statute or =
>regulation adopted prior to such date to verify the identity of an =
>individual."  In addition, I provided him with copies of 5 USC 301 and =
>DOE 35 which specifically require the use of SSN in dosimetry records.  Th=
>e equivalent ones for ERDA do not specify the disclosure of the SSN (ERDA =
>30 and 10CFR Chapter III, Part 708), but do state that records must be =
>retrievable by name, alphabetically, numerically, alphanumerically, and =
>chronologically.  Now, however, he is arguing that since the Department =
>of Energy was not in existence prior to January 1, 1975 that these =
>regulations do not apply and that since ERDA did not specifically require =
>the use of the SSN, he does not have to provide me with this information. =
> The question is where do I go from here?  I have already solicited the =
>aid of several individuals within the DOE - FRMI Group.  Has anyone else =
>encountered this problem?  Any leads on where to find documentation on =
>the use of SSN for dosimetry records within ERDA or the AEC?  Thanks for =
>the help.
>
>Elaine Marshall
>Fermi National Accelerator Laboratory
>P.O. Box 500
>Batavia, IL  60510-0500
>FAX  (630)840-3390
>Phone:  (630)840-8756
>email to emarshall@fnal.gov
>
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