Question: Hi Paula – Do you know of a regulation or rationale why ACL does not want to see social security numbers in CSRs?  Does it have to do with HIPAA privacy regulations?  Please inform.  Thanks –

Reply: Yes, it has to do with privacy and the fact that the CIL almost never has a reason to have that information floating around in the office where the individual’s identity can be stolen. (Of course, we hope your records are carefully secured, but sometimes when staff are working in a file it is in the open on a desk. Sometimes more than one staff person can access the electronic record.) The easiest way to safeguard personal information is not to collect it in the first place unless you need to do so. Often, though, the social security number or driver’s license number are on the CIL’s intake form or in the computer data base. I tell people not to fill in that field in the consumer data unless they are assisting the person with a social security matter. Can you think of any other reason they would need to see it?

 “Need to know” is the basis for the decision that it is not needed.

How much private, personal information do we need in the Consumer Service Record?

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