Gusto collects government-issued identifiers including Social Security numbers, tax IDs, and driver's license numbers as part of payroll and identity verification processes.
This analysis describes what Gusto's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The clause establishes Gusto's authority to collect government-issued identification as part of its verification and compliance procedures for employer accounts, enabling identity confirmation and regulatory compliance processes.
The updated policy explicitly discloses that Gusto sells or shares personal information (defined under state privacy laws) with third parties including business, advertising, and technology partners. The company describes 'sale' as providing information in exchange for valuable consideration, and 'share' as providing information for cross-context behavioral advertising. This disclosure formalizes practices that may have been permitted under previous language but were not explicitly described. You can opt out of sales or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
View change record →The updated Privacy Policy now explicitly states it covers retirement account management (401k, SEP IRA, IRA accounts) and adds Stripe alongside Plaid as a third-party service provider that collects financial institution data. The policy restructures how it describes Gusto's role in different contexts: when Gusto acts as a service provider processing payroll or other data on behalf of employers, when it acts as an employer itself, or when it operates as a co-employer under a professional organization (PEO) arrangement, with separate privacy notices applying in each case. The policy introduces a new commitment that de-identified data will not be re-identified except to verify compliance with applicable law. If you connect a bank account through Stripe, that data will be treated under Stripe's Privacy Policy, which you should review separately.
View change record →Removal of this high-severity provision eliminates specific focus on government ID collection, though such identifiers may now be subsumed under the broader 'Sensitive Personal Information Collection' provision with less explicit emphasis.
View full change record →Your Social Security number and other government IDs are stored by Gusto for payroll tax filing and identity verification. If this data is breached or misused, it could lead to serious identity theft with long-lasting consequences.
How other platforms handle this
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
TAO Toolkit releases that collect data, collect it for the following purposes: (a) to properly configure and optimize products for use with Software; (b) to deliver content or service through the Software; and (c) to improve NVIDIA products...
Some of our ad partners may also enable us to collect similar data directly from their website or app by integrating our or our affiliates' advertising technology.
"We may also require Employer to provide identifying documentation about Employer's business entity, Administrators and signatory, which may include passports, drivers licenses, or other government issued identification.Excerpt from Gusto's Privacy Policy
Collection of SSNs and government IDs is subject to IRS regulations, state-level SSN protection laws, and CCPA/CPRA's sensitive personal information requirements.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The clause establishes Gusto's authority to collect government-issued identification as part of its verification and compliance procedures for employer accounts, enabling identity confirmation and regulatory compliance processes.
Your Social Security number and other government IDs are stored by Gusto for payroll tax filing and identity verification. If this data is breached or misused, it could lead to serious identity theft with long-lasting consequences.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gusto.