BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1168
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          Date of Hearing:   April 17, 2007

                       ASSEMBLY COMMITTEE ON HIGHER EDUCATION
                              Anthony Portantino, Chair
                     AB 1168 (Jones) - As Amended: April 17, 2007
           
          SUBJECT  :   Social security numbers

           SUMMARY  :   Requires specified public agencies, including  
          colleges and universities, to truncate Social Security numbers  
          (SSNs) in any records that might be displayed to the public.   
          Specifically,  this bill  :  

          1)Requires all colleges and universities, located in California  
            to truncate SSNs in their electronic records at both the  
            campus and systemwide levels, so that no more than the last  
            four digits of any SSN are displayed.

             a)   Applies to the University of California (UC) and its  
               campuses only to the extent that its provisions are adopted  
               by the UC Board of Regents.

             b)   Authorizes the Attorney General, or any injured person,  
               to bring a civil action to enforce this provision. 

          2)Prohibits a local agency from disclosing to the public any  
            record that is required to be open to the public by any  
            provision of law if the record displays more than the last  
            four digits of any SSN and makes conforming changes to the  
            Commercial Code relative to the filing of financial statements  
            under the Uniform Commercial Code and the forms required for  
            such filings.

          3)Requires, unless prohibited by federal law, the Franchise Tax  
            Board (FTB) to redact the first five digits of any SSN on lien  
            abstracts or any other public records created by FTB.

           EXISTING LAW  prohibits any person or entity from publicly  
          posting or displaying in any manner an individual's SSN,  
          printing an individual's SSN on any card required to access  
          products or services, requiring an individual to transmit his or  
          her SSN over the Internet, requiring an individual to use his or  
          her SSN to access an Internet Web site or printing an  
          individual's SSN on any materials that are mailed to the  
          individual, excepting documents that are recorded or required to  








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          be open to the public pursuant to the California Public Records  
          Act.

           FISCAL EFFECT  :   Unknown

          COMMENTS  :    Background  : Identity theft occurs whenever someone  
          uses the personal identifying information of another person for  
          an unlawful purpose, including obtaining or attempting to obtain  
          credit, goods, services or medical information in the name of  
          the other person without that person's consent.  According to  
          the Federal Trade Commission (FTC), identity theft has  
          consistently topped the list of consumer fraud complaints for at  
          least the last six years.  The 255,000 complaints of identity  
          theft filed with the FTC in 2005 constituted 37% of all  
          complaints, far surpassing any other single complaint.  The most  
          common form of identity theft is opening a line of credit in the  
          victim's name.  For the identity thief, the SSN is the  
          single-most useful tool.  

           Use of SSNs in higher education  : Existing state privacy law  
          prohibits the public display of SSNs, including printing SSNs on  
          any identification (ID) card needed to access goods or services.  
           The law was written to allow UC, CSU and CCC a delayed  
          implementation; as of January 1, 2007, all three systems must be  
          in compliance.  The law has been credited with ending the  
          practice of printing SSNs on student ID cards at colleges and  
          universities across the state.  

          However, the law explicitly does not prevent or dictate terms  
          for "the collection, use, or release of a SSN as required by  
          state or federal law or the use of a SSN for internal  
          verification or administrative purposes." 

          For a variety of reasons, institutions of higher education  
          collect and maintain a great deal of personal information on  
          students and employees. For example, colleges and universities  
          must maintain student records for several years in order to  
          respond to requests for grade transcripts.  A SSN helps to  
          ensure that transcripts are in fact those of the requesting  
          student, since many students may have common names.  In  
          addition, federal student aid programs use SSNs as the sole  
          student identifier, requiring colleges and universities to use  
          SSNs in order to participate in these programs.  However, this  
          vast amount of personal information-whether it is maintained in  
          on-campus computer databases or code-accessible websites-is  








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          subject to "hacking" or can otherwise fall into the hands of  
          unauthorized persons.  

           Recent examples of data breaches at California colleges and  
          universities  : UC has recently been the victim of two large data  
          breaches that exposed the SSNs of students, faculty, employees  
          and, in some cases, even applicants-800,000 affected individuals  
          in a University of California, Los Angeles case in December and  
          46,000 affected individuals in a UC San Francisco (UCSF) case  
          this month.  UC is not alone: A list of security breaches  
          maintained and frequently updated by the Privacy Rights  
          Clearinghouse contains a disproportionate number of colleges and  
          universities, including the following:   

          1)April 6, 2005, at UCSF: A server in the accounting and  
            personnel departments was hacked that contained information on  
            7,000 students, faculty and staff members; 

          2)August 17, 2005, at CSU Stanislaus: Hacking exposed 900  
            records;

          3)August 30, 2005, at CSU Chancellor's Office: Hacking exposed  
            154 records;

          4)July 14, 2006, at Cal Poly San Luis Obispo: A laptop computer  
            was stolen from the home of a physics department professor  
            July 3, that included the names and SSNs of physics and  
            astronomy students from 1994-2004;

          5)November 28, 2006, at CSU Los Angeles Charter School of  
            Education: An employee's USB drive was inside a purse stolen  
            from a car trunk. It contained personal information on 48  
            faculty members and more than 2,500 students and applicants of  
            a teacher credentialing program, including names, SSNs, campus  
            ID numbers, phone numbers and e-mail addresses;

          6)February 15, 2007, at City College of San Francisco (CCSF):  
            Names, grades and SSNs were posted on an unprotected Web site  
            after summer session in 1999. CCSF stopped using SSNs as  
            student ID cards in 2002, affecting 11,000 records; and,  

          7)March 7, 2007, at Los Rios Community College: Student  
            information including SSNs was accessible on the Internet  
            after the school used actual data to test a new online  
            application process in October, affecting 2,000 records.








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           Need for the bill  : According to the author, the state's policy  
          should be to minimize both the collection and storage of this  
          information at colleges and universities, given the odds of it  
          being released to unauthorized viewers, by prohibiting the use  
          of all but the last four digits of the SSN and by requiring  
          colleges and universities to discard records and applications  
          after a reasonable period of time if those records contain SSNs  
          along with other pieces of personally identifiable information. 

           Related legislation  : AB 381 (Galgiani), pending in the Assembly  
          would allow a hospital-based physician to submit to the state  
          Medi-Cal program a reimbursement claim or an eligibility  
          verification request containing a patient's SSN.  AB 703  
          (Ruskin), pending in the Assembly, would prohibit a person or  
          entity from using a SSN as an identifier, except as required by  
          federal or state law, would require that records containing SSNs  
          be discarded or destroyed in a specified manner and would  
          require the encryption or locked storage of records containing  
          SSNs.  SB 216 (Cox), pending in the Senate, would delete the  
          requirement that abstracts of judgment requiring the payment of  
          money or ordering a party to pay spousal, child or family  
          support contain the SSN and would instead require that they  
          contain only the last four digits of the SSN.  SB 644 (Correa),  
          pending in the Senate, would remove the requirement that  
          abstracts of judgment contain the SSN of the judgment debtor,  
          instead requiring only the last four digits of the number and  
          would provide that tax lien abstracts filed with as public  
          records only must only contain the last four digits of the SSN.   
          SB 741 (Ackerman), pending in the Senate, would encourage a  
          school district or a school that has the ability to omit the SSN  
          and birth date of a pupil from materials sent by the school  
          district or school of attendance of a pupil to the residence of  
          the pupil to do so.  SB 904 (Battin), pending in the Senate,  
          would require a county recorder upon request by a veteran to  
          redact the address, date of birth and SSN from military  
          discharge records and certificates or statements of military  
          service.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file.









                                                                  AB 1168
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           Opposition 
          
          None on file.
           
          Analysis Prepared by  :    Sandra Fried / HIGHER ED. / (916)  
          319-3960