New York Blood Center requires SSN to donate [priv]

[Declan McCullagh <declan () well com>]

-------- Original Message --------
Subject: NY Blood Center Requires SS# to Donate
Date: Tue, 27 Apr 2004 12:09:31 -0400
From: talcottk () optonline net
To: declan () well com
CC: rjones () nybloodcenter org

Declan:

I went today to do my civic duty by donating blood -- the New York Blood 
Center is calling for 2000 donations each day to make up a blood 
shortage in this area.  Unfortunately, the Blood Center refused to 
accept my blood without also taking my Social Security number.  As a 
result, they got neither.

Their rationale (from the www.nybloodcenter.org website, where on the 
FAQ page the heading "Social Security Number and Blood Donation" is 
highlighted in large red letters above all of the other FAQs) is 
followed by my comments:

"The New York Blood Center uses social security numbers to uniquely 
identify donors, so that we can maintain a computerized record of each 
donor and all of the donations they have given to our organization."

Comment: Of course one could devise any number of schemes to uniquely 
identify donors.  Other blood banks will allow one to make up a unique 
identifier; similarly, the NY Blood Center could simply assign a unique 
identifier to the applications of each person who did not want to donate 
their SS# along with their blood.

"After a person has donated blood for the first time a NYBC Donor Card 
with a unique "Donor Number" will be issued. Repeat donors may use this 
unique Donor Number in lieu of a social security number for any future 
donations, provided they present their signed donor ID card at the time 
of donation."

Comment: This does not change the fact that the NY Blood center will 
have my SS# in its database, which is something I was trying to avoid.

"The New York Blood Center uses social security numbers to uniquely 
identify donors, so that we can maintain a computerized record of each 
donor and all of the donations they have given to our organization. The 
purpose of unique records is to protect the safety of the blood supply. 
For example, we need to know that if a donor who is ineligible donates 
blood, it must be discarded. We need to be able to trace previous 
donations from a donor who subsequently tests positive on one of the 
blood screening tests."

Comment: There appears to be a legitimate need to have a unique 
identifier for each donor.  This does not justify selecting the donor's 
SS# as that identifier.

"The federal Social Security Act states that blood collection 
organizations may use social security numbers as unique donor 
identifiers. It is fair to say that social security number is used 
throughout the country in this way. An acceptable alternative to social 
security number is passport or visa number."

Comment: The many organizations that use SS#s to identify people, 
coupled with the failure of those organizations to safeguard those 
numbers, has given rise to the justifiable reluctance of those same 
people to part with their numbers.

"Law at the state level addresses protection of blood donor 
confidentiality. We only release information about blood donors if 
required by law, such as Dept of Health reporting of various test 
results, or by court order. We never share information about donors with 
their employer, insurance company, financial agencies, etc. This 
includes demographic data such as social security number."

Comment: Since when did my SS# become "demographic data"?

"Multiple levels of access codes and passwords protect our computerized 
donor records."

Comment:  (1) Prove it.  (2) Can you say "encryption"?

"We have never had a breach in confidentiality of records."

Comment: Can you say "hacker invitation"?

Obviously this requirement has become a problem for the NY Blood Center. 
 Maybe now would be a good time for them to devise a new scheme that 
would create a truly unique identifier for each of their donors, and to 
eliminate Social Security numbers from their records.

Regards,

Kelly Talcott


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