It is the policy of the Manchester Soccer Club to protect the confidentiality of Social Security numbers obtained and used in the course of business from its employees, applicants, players, coaches, referees, administrators and volunteers. All executives, managers and employees are expected to rigorously adhere to this policy. Any person associated with and/or employed by the Club, found to be violating the provisions of this policy and its operating procedures, will be disciplined in accordance with Club rules.

Operating Procedures

1. Collection of Numbers: Social Security numbers will be collected from applicants and employees as required in order to meet federal and/or state reporting requirements. In addition, Social Security numbers may be collected from players, coaches, referees, administrators and volunteers as required for risk management controls. These purposes include:
• To conduct background checks.
• To verify eligibility for employment.
• To verify eligibility for membership.
• To withhold federal and state taxes.
• To comply with state new hire reporting.
• To facilitate enrollment in company benefit plans.

Note: Social Security numbers may also be collected from creditors, suppliers or independent contractors where no tax identification or employer identification number is accessible. Social Security numbers so obtained will be subject to the same provisions of the privacy policy as those for applicants and employees.

2. Use of Numbers: Except for verification and reporting uses for the above referenced reasons, no Social Security number or portion of a Social Security number will be used in the conduct of the Club’s business and
• No Social Security number or portion of a Social Security number will be permitted to be used for the following purposes: identification badges – including player and coach passes, team rosters, time cards, employee rosters, employee identification records, computer passwords, company account records, licenses, agreements or contracts.
• No Social Security number or portion of a Social Security number will be used in open computer transmissions, Club distributions or through the Club intranet except where such transmission of information is by secure connection or is encrypted. As examples, reporting of payroll withholding taxes and benefit plan participation require such data; thus, such transmissions of data will be handled through secured computer transmission only.

3. Storage of and Access to Numbers:
Storage: All documents containing Social Security numbers shall be stored in locked, secured areas. All computer applications containing Social Security numbers shall be maintained on secured, authorized access computer stations only.
Access: Only persons who have a legitimate business reason will have access to Social Security numbers; such access will be granted through executives responsible for functions with reporting or transporting of such data responsibilities. Executives and employees granted such access must take all necessary precautions to ensure the integrity of records that include such numbers when the records are not being used.

4. Destruction of Numbers: Records that include Social Security numbers will be maintained in accordance with federal and state laws. When such documents are released for destruction, th e records will be destroyed by shredding.

5. State Laws: Where this Club policy and operating procedures may conflict with a state law, the state law shall supersede this policy.