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Combined Federal Campaign Reference Materials

CFC MEMORANDUM 2007-8

October 1, 2007

TO: LOCAL FEDERAL COORDINATING COMMITTEES AND PRINCIPAL COMBINED FUND ORGANIZATIONS
FROM: MARK LAMBERT
ACTING DIRECTOR, OFFICE OF CFC OPERATIONS
SUBJECT: Use Of Social Security Numbers And Employee Identification Numbers For Civilian, Military And Postal Employees

The United States Postal Service (USPS) has informed us the Postal payroll providers now can process CFC pledge forms using either the Postal employee Social Security Number (SSN) or the eight-digit Postal Employee Identification Number (EIN) on the CFC pledge form.   Payroll deduction pledges must contain either the SSN or the Postal EIN to be processed by Postal payroll offices.

In accordance with the Privacy Act Notice (printed on the last page of all CFC pledge forms), the use of SSNs is voluntary.  All employees may continue to opt out of disclosing their SSN on the CFC pledge form.  However, civilian and military payroll offices continue to advise us that without the SSN the payroll deduction might not be processed.

Campaigns are reminded that it is not permissible to collect, store, or temporarily use a donor’s SSN.  Any campaign collecting or storing donor SSNs must immediately remove and permanently destroy such records, whether held in electronic or paper format.   If SSNs have been collected in campaigns prior to the 2007 CFC (e.g., on pledge forms or in accounting systems), it is permissible to maintain the information in accordance with CFC record retention regulation 5 CFR § 950.604; however, campaigns should provide appropriate security controls to protect the confidentiality of the SSNs (e.g., pledge forms should be maintained in a locked area with limited accessibility by staff and/or accounting systems should be protected via restricted user id/password).  CFC campaigns not in compliance are subject to sanctions and penalties as provided in CFC Regulations at 5 CFR § 950.603(a)(1).

Your cooperation in protecting donor privacy and preventing identity theft is appreciated. Questions and comments on this guidance should be directed to Cherlynn Stevens at casteven@opm.gov.

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