Last-modified: April 2, 1995
Last-Modification: new Archive name, retrieval directions, employers, banks
URL: http://www.cpsr.org/cpsr/privacy/ssn/html/privacy.html
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If you have comments on the following, please send them to me at
hibbert@netcom.com. A description of how to retrieve the most recent
version of this and related documents appears at the end.
What to do when they ask for your Social Security Number
by Chris Hibbert
Computer Professionals
for Social Responsibility
Many people are concerned about the number of organizations asking for their
Social Security Numbers. They worry about invasions of privacy and the
oppressive feeling of being treated as just a number. Unfortunately, I can't
offer any hope about the dehumanizing effects of identifying you with your
numbers. I *can* try to help you keep your Social Security Number from being
used as a tool in the invasion of your privacy.
Dealing with Government Organizations
Surprisingly, government agencies are reasonably easy to deal with; private
organizations are much more troublesome. Federal law restricts the agencies
at all levels of government that can demand your number and a fairly complete
disclosure is required even if the disclosure is voluntary. There are no
comparable Federal laws either restricting the uses non-government
organizations can make of it, or compelling them to tell you anything about
their plans. Some states have recently enacted regulations on collection of
SSNs by private entities. With private institutions, your main recourse is
refusing to do business with anyone whose terms you don't like. They, in
turn, are allowed to refuse to deal with you on those terms.
Universities and Colleges
Universities that accept federal funds are subject to the Family Educational
Rights and Privacy Act of 1974 (the "Buckley Amendment", it's on-line at |
http://www.cpsr.org/cpsr/privacy/law/education_records_privacy.txt), which
prohibits them from giving out personal information on students without
permission. There is an exception for directory information, which is
limited to names, addresses, and phone numbers, and another exception for
release of information to the parents of minors. There is no exception for
Social Security Numbers, so covered Universities aren't allowed to reveal
students' numbers without their permission. In addition, state universities
are bound by the requirements of the Privacy Act, (so they have to give a
Privacy Act notice if they ask for a SSN). If they make uses of the SSN
which aren't covered by the disclosure they are in violation.
US Passports
The application for US Passports (DSP-11 12/87) requests a Social Security
Number, but doesn't give enough information in its Privacy Act notice to
verify that the Passport office has the authority to request it. There is a
reference to "Federal Tax Law" and a misquotation of Section 6039E of the
1986 Internal Revenue Code, claiming that that section requires that you
provide your name, mailing address, date of birth, and Social Security
Number. The referenced section only requires TIN (SSN), and it only requires
that it be sent to the IRS (not to the Passport office). It appears that
when you apply for a passport, you can refuse to reveal your SSN to the
passport office, and instead mail a notice to the IRS, give only your SSN
(other identifying info optional) and notify them that you are applying for a
passport. [Copies (in postscript) of the letter that was used by one
contributor can be found at
http://www.cpsr.org/cpsr/privacy/ssn/passport.ps.Z. I've since heard from |
other readers who have also used this technique successfully.] |
Health Plans requiring SSNs for covered minors
I have recently gotten several reports of a new Federal requirement that
employer-provided health plans must get employees to provide the SSNs of all
covered dependents, including minor children. I don't have complete or
authoritative information on this yet, but it seems that the Omnibus Budget
Reconciliation Act of 1993 required employers to collect social security
numbers for each plan participant, including dependents. The part that
bureaucrats weren't reporting was that this requirement wasn't supposed to go|
into effect until January, 1995.
[March 95: I haven't heard anything recently about it. No requests for SSNs,|
no word about cancelling the program.] |
Fighting the requirement in your company
According to a note in the Federal Register on May 10, 1994, the department
of Health and Human Services requested that the requirements be delayed for
18 months in order that the requirements could be made more consistent with
(then impending) health care reform legislation. I don't know whether
the delay was ever implemented, but you can probably keep your HR department
busy by telling them that HHS wanted a delay. You can also point them at the
compliance requirements in HHS' proposed regulations; they require only a
good faith effort on the employer's part, and even define what that is.
"An employer is deemed to have made a reasonable good faith
effort to provide the information with respect to the name and
TIN of each other individual covered by the group health plan
with respect to the reports for a specific calendar year if the
employer can prove that it has established a systematic method
to obtain the necessary information that includes both (i) a
documented initial effort to obtain the necessary information
from the electing individual and (ii) a documented follow-up
effort if the electing individual does not respond to the
initial effort."
In any case, when the federal government requires your employer to collect
SSNs from you, it has to provide a form with a Privacy Act notice. If your
personnel department asks you to give them your dependents' SSNs, ask to see
a Privacy Act notice. If necessary, ask them to look at the statement on W-4
forms and tell them that they need a statement like it in order for the
request to be legal.
Children
The Family Support Act of 1988 (Pub. L. 100-485) requires states to require
parents to give their Social Security Numbers in order to get a birth
certificate issued for a newborn. The law allows the requirement to be
waived for "good cause", but there's no indication of what may qualify.
The IRS requires taxpayers to report SSNs for dependents over one year of age
when you claim them as a deduction, but the requirement can be avoided if
you're prepared to document the existence of the child by other means if the
IRS challenges you. The law on this can be found at 26 USC 6109. The
penalty for not giving a dependent's number is only $5. Several people have
reported that they haven't provided SSNs for their dependents for several
years, and haven't been challenged by the IRS.
Private Organizations
The guidelines for dealing with non-governmental institutions are much more
tenuous. Most of the time private organizations that request your Social
Security Number can get by quite well without your number, and if you can
find the right person to negotiate with, they'll willingly admit it. The
problem is finding that right person. The person behind the counter is often
told no more than "get the customers to fill out the form completely."
Most of the time, you can convince them to use some other number. Usually
the simplest way to refuse to give your Social Security Number is simply to
leave the appropriate space blank. One of the times when this isn't a strong
enough statement of your desire to conceal your number is when dealing with
institutions which have direct contact with your employer. Most employers
have no policy against revealing your Social Security Number; they apparently
believe that it must be an unintentional slip when an employee doesn't
provide an SSN to everyone who asks.
Employers |
Employers are required by the IRS to get the SSNs of people they hire. They |
often ask for it during the interview process, but there are good reasons to |
refuse if you can afford to argue with the potential employer. Some of them |
use the SSN to check credit records, to look for criminal history, and |
otherwise to delve into your past in areas you might object to. Tell them |
you'll give them your SSN when you accept their offer. They have no |
legitimate use for it before then. |
Utilities |
Public utilities (gas, electric, phone, etc.) are considered to be private
organizations under the laws regulating SSNs. Most of the time they ask for
an SSN, and aren't prohibited from asking for it, but they'll usually relent
if you insist. See the other suggestions below under "What you can do to
protect your number" for more ideas.
Banks |
Banks and various others are required by the IRS to report the SSNs of |
account holders to whom they pay interest. If you don't tell them your |
number you will probably either be refused an account or be charged a penalty|
such as withholding of taxes on your interest. |
Most banks send your name, address, and SSN to a company called ChexSystem
when you open an account. ChexSystem keeps a database of people whose
accounts have been terminated for fraud or chronic insufficient funds in the
past 5 years. ChexSystems is covered by the Fair Credit Reporting Act, and
the bank is required to let you know if it refuses to open your account and a
report from ChexSystems was a factor. You can also send a letter to
ChexSystems directly (Consumer Relations, 1550 E. 79th Street, Suite 700,
Minneapolis, MN 55425) and request a copy of their report on you.
Many Banks, Brokerages, and other financial institutions have started
implementing automated systems to let you check your balance. All too often,
they are using SSNs as the PIN that lets you get access to your personal
account information. If your bank does this to you, write them a letter
pointing out how common it is for the people with whom you have financial
business to know your SSN. Ask them to change your PIN, and if you feel like
doing a good deed, ask them to stop using the SSN as a default identifier for
their other customers. Some customers will believe that there's some
security in it, and be insufficiently protective of their account numbers.
Sometimes banks provide for a customer-supplied password, but are reluctant
to advertise it. The only way to find out is to ask if they'll let you
provide a password. (This is reportedly true of Citibank Visa, for instance.
They ask for a phone number but are willing to accept any password.)
When buying (or refinancing) a house, you have to give your number, because |
the bank is required to report the interest you pay. Most banks will now ask|
for your Social Security Number on the Deed of Trust. This is because the
Federal National Mortgage Association requires it. The fine print in their
regulation admits that some consumers won't want to give their number, and
allows banks to leave it out when pressed. [It first recommends getting it
on the loan note, but then admits that it's already on various other forms
that are a required part of the package, so they already know it. The Deed
is a public document, so there are good reasons to refuse to put it there,
even though all parties to the agreement already have access to your number.]
Insurers, Hospitals, Doctors
No laws require private medical service providers to use your Social Security
Number as an ID number. They often use it because it's convenient or because
your employer uses it to identify employees to its groups health plan. In
the latter case, you have to get your employer to change their policies.
Often, the people who work in personnel assume that the employer or insurance
company requires use of the SSN when that's not really the case. When a
previous employer asked for my SSN for an insurance form, I asked them to
find out if they had to use it. After a week they reported that the
insurance company had gone along with my request and told me what number to
use.
Most insurance companies share access to old claims through the Medical
Information Bureau. If your insurance company uses your SSN, other insurance
companies will have a much easier time finding out about your medical
history. You can get a copy of the file MIB keeps on you by writing to
Medical Information Bureau, P.O. Box 105, Essex Station, Boston, MA 02112.
Their phone number is (617)426-3660.
If an insurance agent asks for your Social Security Number in order to "check
your credit", point out that the contract is invalid if your check bounces or
your payment is late. Insurance is always prepaid, so they don't need to
know what your credit is like, just whether your check cleared.
Blood banks
Blood banks also ask for the number but are willing to do without if pressed
on the issue. After I asked politely and persistently, the (non-Red Cross)
blood bank I go to agreed that they didn't have any use for the number.
They've now expunged my SSN from their database, and they seem to have taught
their receptionists not to request the number. I've gotten one report that
some branches of the Red Cross will issue a "file number" in lieu of your SSN
if you insist. It's probably the case that not all branches (and especially
not all receptionists) know about this possibility, so it will pay to be
persistent.
Blood banks have changed their policies back and forth a few times in the
last several years. When the AIDS epidemic first hit, they started using
SSNs to identify all donors, so someone who was identified as HIV-positive at
one blood bank wouldn't be able to contaminate the blood supply by donating
at a different site. For a few years, they were a little looser, and though
they usually asked for SSNs, some would allow you to donate if you provided
proof of your identity. (I showed a Driver's license, but didn't let them
copy down the number.) Now the Federal Government has declared blood banks
to be "manufacturers" of a medical product, and imposed various Quality
Control processes on them.
The Blood bank I go to now asks for SSNs, and if you refuse, allows you to
give a Driver's License number. I balked at that, since I hadn't had to give
it before. They let me donate, but while I was eating cookies, the director
of Quality Control came down and talked to me. After a little bit of
discussion, she was satisfied to have me pick an ID number that I promised to
remember and provide when I visisted again. So, once again, if you want to
protect your SSN and your privacy, it pays to push back when they ask.
Short History
Social Security numbers were introduced by the Social Security Act of 1935.
They were originally intended to be used only by the social security program.
In 1943 Roosevelt signed Executive Order 9397 which required federal agencies
to use the number when creating new record-keeping systems. In 1961 the IRS
began to use it as a taxpayer ID number. The Privacy Act of 1974 required
authorization for government agencies to use SSNs in their data bases and
required disclosures (detailed below) when government agencies request the
number. Agencies which were already using SSN as an identifier before
January 1, 1975 were allowed to continue using it. The Tax Reform Act of
1976 gave authority to state or local tax, welfare, driver's license, or
motor vehicle registration authorities to use the number in order to
establish identities. The Privacy Protection Study Commission of 1977
recommended that EO9397 be revoked after some agencies referred to it as
their authorization to use SSNs. It hasn't been revoked, but no one seems to
have made new uses of the SSN recently and cited EO9397 as their sole
authority, either.
Several states use the SSN as a driver's license number, while others record
it on applications and store it in their database. Some states that
routinely use it on the license will make up another number if you insist.
According to the terms of the Privacy Act, any that have a space for it on
the application forms should have a disclosure notice. Many don't, and until
someone takes them to court, they aren't likely to change.
The Privacy Act of 1974 (Pub. L. 93-579, in section 7) requires that any
federal, state, or local government agency that requests your Social Security
Number has to tell you four things:
1: Whether disclosure of your Social Security Number is required or
optional,
2: What statute or other authority they have for asking for your number,
3: How your Social Security Number will be used if you give it to them, and
4: The consequences of failure to provide an SSN.
In addition, the Act says that only Federal law can make use of the Social
Security Number mandatory (at 5 USC 552a note). So anytime you're dealing
with a government institution and you're asked for your Social Security
Number, just look for the Privacy Act Statement. If there isn't one,
complain and don't give your number. If the statement is present, read it.
If it says giving your Social Security Number is voluntary, you'll have to
decide for yourself whether to fill in the number.
Why SSNs are a bad choice for UIDs in data bases
Database designers continue to introduce the Social Security Number as the
key when putting together a new database or when re-organizing an old one.
Some of the qualities that are (often) useful in a key and that people think
they are getting from the SSN are uniqueness, universality, security, and
identification. When designing a database, it is instructive to consider
which of these qualities are actually important in your application; many
designers assume unwisely that they are all useful for every application,
when in fact each is occasionally a drawback. The SSN provides none of them,
so designs predicated on the assumption that it does provide them will fail
in a variety of ways.
Uniqueness
Many people assume that Social Security Numbers are unique. They were
intended by the Social Security Administration to be unique, but the SSA
didn't take sufficient precautions to ensure that it would be so. They have
several times given a previously issued number to someone with the same name
and birth date as the original recipient, thinking it was the same person
asking again. There are a few numbers that were used by thousands of people
because they were on sample cards shipped in wallets by their manufacturers.
(One is given below.)
The passage of the Immigration reform law in 1986 caused an increase in the
duplicate use of SSNs. Since the SSN is now required for employment, illegal
immigrants must find a valid name/SSN pair in order to fool the INS and IRS
long enough to collect a paycheck. Using the SSN when you can't cross-check
your database with the SSA means you can count on getting some false numbers
mixed in with the good ones.
Universality
Not everyone has a Social Security Number. Foreigners are the primary
exception, but many children don't get SSNs until they're in school (and some
not until they get jobs). They were only designed to be able to cover people
who were eligible for Social Security. If your database will keep records on
organizations as well as individuals, you should realize that they're not
covered either.
Identification
Few people ever ask to see an SSN card; they believe whatever you say. The
ability to recite nine digits provides little evidence that you're associated
with the number in anyone else's database.
There's little reason to carry your card with you anyway. It isn't a good
form of identification, and if your wallet is lost or stolen, it provides
another way for the thief to hurt you.
Security
Older cards are not at all forgery-resistant, even if anyone did ever ask for
it. (Recently-issued cards are more resistant to forgery.) The numbers
don't have any redundancy (no check-digits) so any 9-digit number in the
range of numbers that have been issued is a valid number. It's relatively
easy to write down the number incorrectly, and there's no way to tell that
you've done so.
In most cases, there is no cross-checking that a number is valid. Credit
card and checking account numbers are checked against a database almost every
time they are used. If you write down someone's phone number incorrectly,
you find out the first time you try to use it. An incorrect SSN might go
unnoticed for years in some databases. In others it will likely be caught at
tax time, but could cause a variety of headaches.
Why you should resist requests for your SSN
When you give out your number, you are providing access to information about
yourself. You're providing access to information that you don't have the
ability or the legal right to correct or rebut. You provide access to data
that is irrelevant to most transactions but that will occasionally trigger
prejudice. Worst of all, since you provided the key, (and did so
"voluntarily") all the info discovered under your number will be presumed to
be true, about you, and relevant.
A major problem with the use of SSNs as identifiers is that it makes it hard
to control access to personal information. Even assuming you want someone to
be able to find out some things about you, there's no reason to believe that
you want to make all records concerning yourself available. When multiple
record systems are all keyed by the same identifier, and all are intended to
be easily accessible to some users, it becomes difficult to allow someone
access to some of the information about a person while restricting them to
specific topics.
Unfortunately, far too many organizations assume that anyone who presents
your SSN must be you. When more than one person uses the same number, it
clouds up the records. If someone intended to hide their activities, it's
likely that it'll look bad on whichever record it shows up on. When it
happens accidentally, it can be unexpected, embarrassing, or worse. How do
you prove that you weren't the one using your number when the record was
made?
What you can do to protect your number
If despite your having written "refused" in the box for Social Security
Number, it still shows up on the forms someone sends back to you (or worse,
on the ID card they issue), your recourse is to write letters or make phone
calls. Start politely, explaining your position and expecting them to
understand and cooperate. If that doesn't work, there are several more
things to try:
1: Talk to people higher up in the organization. This often works
simply because the organization has a standard way of dealing
with requests not to use the SSN, and the first person you deal
with just hasn't been around long enough to know what it is.
2: Enlist the aid of your employer. You have to decide whether talking
to someone in personnel, and possibly trying to change
corporate policy is going to get back to your supervisor and
affect your job.
3: Threaten to complain to a consumer affairs bureau. Most newspapers
can get a quick response. Ask for their "Action Line" or
equivalent. If you're dealing with a local government agency,
look in the state or local government section of the phone book
under "consumer affairs." If it's a federal agency, your
congressmember may be able to help.
4: Insist that they document a corporate policy requiring the number.
When someone can't find a written policy or doesn't want to
push hard enough to get it, they'll often realize that they
don't know what the policy is, and they've just been following
tradition.
5: Ask what they need it for and suggest alternatives. If you're
talking to someone who has some independence, and they'd like
to help, they will sometimes admit that they know the reason
the company wants it, and you can satisfy that requirement a
different way.
6: Tell them you'll take your business elsewhere (and follow through if
they don't cooperate.)
7: If it's a case where you've gotten service already, but someone
insists that you have to provide your number in order to have a
continuing relationship, you can choose to ignore the request
in hopes that they'll forget or find another solution before
you get tired of the interruption.
If someone absolutely insists on getting your Social Security Number, you may
want to give a fake number. There are legal penalties for providing a false
number when you expect to gain some benefit from it. A federal court of
appeals ruled that using a false SSN to get a Driver's License violates the
federal law.
There are a few good choices for "anonymous" numbers. Making one up at
random is a bad idea, as it may coincide with someone's real number and cause
them some amount of grief. It's better to use a number like 078-05-1120,
which was printed on "sample" cards inserted in thousands of new wallets sold
in the 40's and 50's. It's been used so widely that both the IRS and SSA
recognize it immediately as bogus, while most clerks haven't heard of it.
The Social Security Administration recommends that people showing Social
Security cards in advertisements use numbers in the range 987-65-4320 through
987-65-4329.
There are several patterns that have never been assigned, and which therefore
don't conflict with anyone's real number. They include numbers with any
field all zeroes, and numbers with a first digit of 8 or 9. For more details
on the structure of SSNs and how they are assigned, see |
http://www.cpsr.org/cpsr/privacy/ssn/SSN-structure. |
Giving a number with an unused pattern rather than your own number isn't very
useful if there's anything serious at stake since it's likely to be noticed.
If you're designing a database or have an existing one that currently uses
SSNs and want to use numbers other than SSNs, you should make your
identifiers use some pattern other than 9 digits. You can make them longer
or shorter than that, or include letters somewhere inside. That way no one
will mistake the number for an SSN.
The Social Security Administration recommends that you request a copy of your
file from them every few years to make sure that your records are correct
(your income and "contributions" are being recorded for you, and no one
else's are.) As a result of a recent court case, the SSA has agreed to
accept corrections of errors when there isn't any contradictory evidence, SSA
has records for the year before or after the error, and the claimed earnings
are consistent with earlier and later wages. (San Jose Mercury News, 5/14,
1992 p 6A) Call the Social Security Administration at (800) 772-1213 and ask
for Form 7004, (Request for Earnings and Benefit Estimate Statement.)
Collecting SSNs yourself
There aren't any federal laws that explicitly forbid the collection of SSNs.
However, there is a body of law, intended to prohibit the misuse of credit
cards, that is written vaguely enough that it could be interpreted to cover
personal collections of SSNs. The laws are at 18 USC 1029, and cover what is
called "access device fraud." An access device is "any card, plate, code,
account number or other means of access that can be used, alone or in
conjunction with another access device, to obtain money, goods, services, or
any other thing of value, or that can be used to initiate a transfer of
value." The law forbids the possession, "knowingly and with intent to defraud"
of fifteen or more devices which are counterfeit or unauthorized access
devices." If interstate commerce is involved, penalties are up to $10,000
and 10 years in prison.
When All Else Fails
(Getting a Replacement Number)
The Social Security Administration (SSA) will occasionally issue a
replacement SSN. The most common justification is that the SSA or the IRS
has mixed together earnings records from more than one person, and since one
of the people can't be located, it's necessary to issue a new number to the
other. The SSA tries very hard to contact the person who is using the number
incorrectly before resorting to this process.
There are a few other situations that the SSA accepts as justifying a new
number. The easiest is if the number contains the sequences 666 or 13. The
digits need to be consecutive according to SSA's policy manual, but may be
separated by hyphens. You apparently don't have to prove that your religious
objection is sincere. Other commonly accepted complaints include that
someone who is harassing you is tracing you through your SSN, sequential
numbers assigned to family members, or serious impact on your credit history
that you've tried to clear up without success.
In all cases, the process includes an in-person interview at which you have
to establish your identity and show that you are the original assignee of the
number. The decision is normally made in the local office. If the problem
is with a credit bureau's records, you have to show that someone else
continues to use your number, and that you tried to get the credit bureau to
fix your records but were not successful. When they do issue a new number,
the new records are linked to the old ones. (Unless you can convince them
that your life might be endangered by such a link.)
There are a few justifications that they don't accept at all: attempting to
avoid legal responsibilities, poor credit record which is your own fault,
lost SSN card (without evidence that someone else has used it), or use of
the number by government agencies or private companies.
The only justification the SSA accepts for cancelling the issuance of an SSN
is that the number was assigned under their Enumeration at Birth (wherein
SSNs are assigned when birth certificates are issued) program without the
parent's consent. In this case, the field officer is instructed to try very
hard to convince the parent that getting the number revoked is futile, but to
give in when the parent is persistent.
Recent Legal News
The Ohio Supreme Court ruled October 26 that SSNs of public employees are not
public records, and so the city of Akron acted correctly in not disclosing
them in response to a request from the Akron Beacon Journal. The newspaper
had asked for copies of the city's employee master files, and the city had
provided the bulk of the records, but had deleted the SSNs on privacy
grounds. EPIC, on behalf of CPSR, wrote a friend of the court brief with the
Public Citizen Litigation group arguing in favor of the city. The EPIC brief
was based, in part, on the Greidinger v. Davis case (C.A.4, 1993), 988 F.2d
1344 decided in Virginia in 1993
If you have suggestions for improving this document please send them to me:
Chris Hibbert
hibbert@netcom.com or 1195 Andre Ave.
Mountain View, CA 94040
Retrieving the SSN FAQ and related documents
The SSN FAQ is available from two places: rtfm.mit.edu (by FTP or |
EMail), or cpsr.org (by FTP or http). |
WWW (HTTP) |
Look at http://www.cpsr.org/cpsr/privacy/ssn/html/privacy.html. The HTML |
version of the SSN FAQ stored there contains several resources which I |
haven't included in the plain text version. |
EMail |
You can get the latest version of the SSN FAQ by sending mail to |
mail-server@rtfm.mit.edu with |
send usenet-by-hierarchy/news/answers/privacy/ssn-faq |
as the sole contents of the body. Send a message containing "help" to |
get general information about the mail server. |
FTP |
Connect to ftp.cpsr.org or rtfm.mit.edu, give "anonymous" as your user |
name, and your email address as the password. The URLs are: |
ftp://cpsr.org/ftp/cpsr/privacy/ssn |
ftp://rftm.mit.edu/pub/usenet-by-hierarchy/news.answers/privacy/ssn-faq |
(If you're using ftp directly, the directory you need to look in |
starts with "ftp" or "pub" respectively in these URLs.) |
rtfm.mit.edu is a standard archive which has many other FAQs. |
cpsr.org has other resources on privacy, SSNs, and related subjects. |
Other directories contain information on pending legislation, the 1st |
amendment, computer security, cryptography, FOIA, NII, and CPSR. |
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