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Committee conditionally approves Safety rule 24‑237 after agency agrees to remove Social Security numbers from forms

May 17, 2025 | Administrative Rules, House of Representatives, Committees , Legislative, New Hampshire


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Committee conditionally approves Safety rule 24‑237 after agency agrees to remove Social Security numbers from forms
The Joint Administrative Rules Committee granted conditional approval to a Department of Safety rule package (24‑237) establishing a contact‑person notification program, after the agency agreed to remove Social Security number (SSN) references from rules and forms and to clarify application language.

Office of Legislative Services identified three substantive concerns: (1) whether RSA 541‑A:21 authorizes the agency to require Social Security numbers in rule; (2) missing introductory language for clauses on page 2; and (3) unclear wording on page 3 about which application(s) require a signature. Department of Safety staff — Karen Schlitzer and Jessica McFadzean of the State Police — told the committee they would remove SSN references from both rules and forms, adopt suggested wording to change an introductory clause (replacing “if” with “where”), and clarify the signature requirement. The agency requested an oral conditional approval that mirrored written edits it had submitted.

Representative Hackens Phillips asked about the rationale for requesting SSNs and the implications of broadcasting last four digits over radio; the department said SSNs had been considered because they are a unique identifier in some databases for situations where an individual cannot provide a name or license, but that the proposed system includes alternative identifiers — driver’s license numbers, non‑driver IDs and school IDs — and the agency can proceed without SSNs.

A motion for conditional approval, including the agency’s oral changes, was moved by Representative Veil and seconded by Representative Lynn; the committee approved the conditional request by voice vote. Committee staff advised the agency that if statutory authority is required to retain SSNs, the agency should work with staff to pursue legislative change during the next bill‑filing period.

The committee recorded the conditional approval and directed the agency to implement the agreed edits in the final filing.

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