FCWD strives to protect the confidentiality of its employees and Social Security numbers obtained from its employees and applicants and used in the course of business. All executives, managers and employees are expected to rigorously adhere to this policy.

Social Security numbers may be collected from applicants and employees as required to comply with federal and/or state reporting requirements. These purposes may include but are not limited to:

• Conduct pre-employment background checks.
• Verify eligibility for employment.
• Withhold federal and state taxes.
• Comply with state new hire reporting.
• Facilitate enrollment in company benefit plans.

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.

Except for verification and reporting uses a Social Security number or portion of a Social Security number shall not be used in the conduct of the company’s business and:

• Shall not be permitted to be used for the following purposes: timesheets, employee rosters, employee identification records, computer passwords, company account records, agreements or contracts.

• Shall not be used in open computer transmissions, company distributions or through the company intranet except where such transmission of information is by secure connection or is encrypted. As an example, reporting of payroll withholding taxes and benefit plan participation require such data; thus, such transmissions of data shall be handled through secured computer transmission.

• 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.

• Only persons who have a legitimate business reason shall have access to Social Security numbers; such access shall be granted through department heads responsible for functions with reporting or transporting of such data responsibilities. Department heads and employees granted such access shall take all necessary precautions to ensure the integrity of records that include such numbers when the records are not being used.

Records that include Social Security numbers shall be maintained in accordance with federal and state laws. When such documents are released for destruction, the records shall be destroyed by shredding.