Legal Bulletins

Maryland's Social Security Number Privacy Law, HB 56 - Chapter 521, is effective January 1, 2006. For health insurance policies and contracts in effect before January 1, 2006, compliance is required by January 1, 2006.

The new law prohibits:

• publicly displaying an SSN
• printing an SSN on a card required to access products or services
• requiring an individual to transmit his or her SSN or transmitting an SSN over the Internet
• requiring an individual to use his or her SSN to access an Internet website unless a password is required
• printing an SSN on mailed material
• including an individual's SSN in material that is transmitted electronically or by facsimile to the individual unless the connection is secure or the SSN is encrypted.

There are exceptions. The prohibitions do not apply if state or federal law requires the collection, release or use of an SSN or to including an SSN in a document mailed or electronically transmitted as part of an application or enrollment process or to establish, amend or terminate an account, contract or policy, for internal verification or administrative purposes, or under other specified circumstances.

A business that used an SSN before January 1, 2006, in a manner prohibited by the new law, may continue to use it until January 1, 2009, if the use is continuous and the business provides an annual disclosure form to the individual. An individual's request to stop using an SSN must be honored within 30 days. The first annual disclosure form is required on January 1, 2006.

Please call any member of our Financial Services and Government Relations Group if we can help you comply with this new law.