ROWAN UNIVERSITY POLICY

Title: Use of Social Security Numbers and Personal Identifying Information in Human Subject Research
Subject: Research and Scholarly Activities
Policy No: Res: 2016: 01
Applies: University-Wide
Issuing Authority: President
Responsible official: Vice President for Research
Adopted: 08/29/2016
Last Revision: 04/28/2022
Last Reviewed: 04/28/2022

I.  PURPOSE    PURPOSE

The purpose of this policy is to protect the use of social security numbers and personal identifying information collected for research purposes.

II.   ACCOUNTABILITY

Under the direction of the President, the Vice President for Research shall implement and ensure compliance with this policy.

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1. Rowan University does not permit the use of a SSN as an identifier or match research data sets for any person or entity in any system, except where the SSN is required or permitted by law. The intent of this policy is to protect the personal information of research participants/subjects and provide guidance on the proper handling of Social Security Number (SSN) and Personally Identifying Information maintained by or on behalf of Rowan University.
   1. Coded tissue samples/data sent to collaborators and data received from collaborators or tissue banks should not be labeled with names, birth dates, or medical record number or SSN.
   2. Research participants are not required to provide their SSN except to receive payment as required by Rowan University Accounting Office.
2. The Rowan University Finance Division, Accounts Payable office may require the researchers to obtain specific information including the SSN payment purposes and to meet its obligation to the Internal Revenue Service (IRS).is required by the Internal Revenue Service (IRS) to obtain a W-9, which may include the SSN or Tax Identification Number (TIN), in order to file various 1099 forms with the IRS. Payments in excess of $600 made to research participants/subjects through Accounts Payable are reported annually to the IRS on Form 1099-MISC, Miscellaneous Income. In order to pay research participants/subjects from ClinCard, Accounts Payable requires the following documentation:
   1. Gift Card Recipient Log
   2. Gift Card Payment Acknowledgment Form
   3. IRS Form W-9 – Request for Taxpayer Identification Number and Certification
   4. In order to receive payment, participants/subjects will be asked to provide their SSN and home address on a Payment Verification Form (PVF).
   5. PVF is separate from research consent form. It cannot be linked to research protocol or research data or any other research information gathered during the course of research.
3. When there is use of SSN for payment purposes, all records containing SSN should be stored in a secure place which may include locked file rooms, desks or cabinets or stored in network drives with access limited to those individuals or entities that require access to perform a legitimate university job function.
   1. SSN will be released to entities outside the institution only where permitted or required by law or with the expressed written permission from the individual or where approved by the Office of General Counsel.
   2. Individuals permitted access to SSN will be instructed on the appropriate handling and protection of this data by their management or designated representative.
   3. Subject to applicable document retention policies or unless required by law, when no longer required, paper documents and electronic media containing SSNs must be destroyed or disposed of using methods designed to prevent subsequent use or recovery of information.
   4. Individuals permitted access to personal identifying information (PII) must safeguard the information and destroy the information.
4. In addition to this policy, Rowan University researchers, faculty, students and staff are required to adhere to:
   1. Rowan University's "Acceptable Use Policy" No: ISO:2013:06;
   2. Rowan University's "Information Classification Policy": Information Security Policy No:ISO:2013:07; and,
   3. Rowan University's "Transmission University’s “Transmission of Sensitive Information Policy"Policy”: Information Security Policy No. ISO:2013:05.
   4. The State of New Jersey "Identity “Identity Theft Prevention Act" Act” requires reporting identity theft to local law enforcement agency.
   5. Rowan University’s “Gift Card Policy”: Finance Policy No: FIN:2020:01
5. If there is reason to believe that Identify theft or loss has occurred, the responsible custodian of PII must immediately report the incidence to the Office of Privacy and Compliance.
6. The Institutional Review Board has the ultimate authority on how PII could be used for research purposes.
7. Any exception to the policy should be submitted to the Office of General Counsel.

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ATTACHMENT 1
PAYMENT VERIFICATION FORMS

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Rowan University's Accounts Payable Department requires that researchers obtain the following information from research participants/subjects to meet its obligation to Internal Revenue Service. The attached forms will be submitted to the University Accounts Payable Department. This form cannot be connected to any information collected as part of a research including but not limited to payment for interviews, surveys, questionnaires or participation in a clinical research study or clinical trial.
W-9s are required by the purchasing department to set up an individual in the Banner system. Payments in excess of $600 made to individuals through Accounts Payable are reported annually to the IRS on Form 1099-MISC, Miscellaneous Income. 

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