I recently did a very interesting project doing a data flow analysis and risk assessment of I-9 documents processing for a large multi-national company.
I-9 documents are necessary to ensure that the Department of Homeland Security (DHS) rules, as defined within 8 CFR Part 274a, “Electronic Signature and Storage of Form I-9, Employment Eligibility Verification.”
This generally addresses how to verify the identity of folks working within the U.S. who are not U.S. citizens and do not have social security numbers (SSNs).
So I was interested to see some related news.
On May 24 the governor of Tennessee, Phil Bredesen, signed into law Public Act 07-220, effective upon his signature.
Under this new law Tennessee businesses must reject the taxpayer identification number and request documentation required by the DHS, which you can find within the second link I provided. This prohibition is limited to potential new hires.
A federal tax identification number is very similar to an SSN; as the new Tennessee law states:
“‚ÄúIndividual taxpayer identification number‚Äù means a tax processing number issued by the federal internal revenue service for the purpose of facilitating federal tax reporting by those individuals who are not eligible to obtain a federal social security number. An individual taxpayer identification number is a nine-digit number that has the appearance of a federal social security number (xxx-xx-xxxx), but that always begins with the number nine (9) and includes the number seven (7) or eight (8) as the fourth digit (9xx-7x-xxxx). An individual taxpayer identification number is issued regardless of immigration status and is not a valid form of identification for any purpose other than federal tax processing.”
Are you a Tennessee business? Be sure your HR folks know about this.
Tags: awareness and training, DHS, employee law, government, HR, I-9 documents, Information Security, IT compliance, Phil Bredesen, policies and procedures, privacy, risk management, social security number, state law, taxpayer identification number, Tennessee