Displaying employee social security numbers and addresses on certified payroll reports, which are ultimately public documents, causes privacy and identity theft concerns for many employers and employees – not to mention confusion over reporting requirements. This question was submitted by a blog reader.
The instructions for the Federal WH-347 certified payroll report say – The payrolls submitted shall include the following information:
- Name of each employee
- A unique individually identifiable number for each employee, or as it was suggested, the last 4 digits of the employee social security number
- His/her correct classification Hourly rates of pay, including any cash fringe benefits paid
- Daily and weekly number of hours worked
- Deductions made
- and actual wages paid
Can we accept a unique individually identifiable number on payroll and is there any specific format or requirements for a unique individually identifiable number? Any help or guidance would be appreciated – Mari
Yes, you can accept and display any sort of unique individually identifiable number instead of the employees social security number on the Federal WH-347 certified payroll reporting form. This change, as well as no longer having to display the employees home address, went into effect in January 2009 in an effort to protect the privacy of workers. You can, however, ask and/or be asked to provide full employee information (name, address, and social security numbers). If you are asked for this information, it is my understanding that it may be submitted as an attachment on a separate piece of paper. To my knowledge there are no written specifics as to how the number must be displayed – so be prepared to see a lot of different methods being used.
While this applies to the Federal or WH-347 certified payroll reporting form, you will find that many state specific reporting forms still require you to submit this information on the actual certified payroll report. If you are subject to both Federal and State specific reporting requirements make sure that you provide the correct information on each form – usually the column heading will be fairly specific as to the information that you must provide.
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