Archive-name: privacy/ssn-faq
Last-modified: July 4, 1996
Last-Modification: corrected URL
URL1: http://www.cpsr.org/cpsr/privacy/ssn/ssn.faq.html
URL2: ftp://rtfm.mit.edu/pub/usenet-by-hierarchy/news/answers/privacy/ssn-faq

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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. 

The advice in this FAQ deals primarily with the Social Security Number used 
in the US, though the privacy considerations are equally applicable in many 
other countries.  The laws explained here are US laws.  The advice about 
dealing with bureaucrats and clerks is universal. 

	The Privacy Act of 1974

The Privacy Act of 1974 (Pub. L. 93-579, in section 7), which is the 
primary law affecting the use of SSNs, 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, 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.  Once
you've read the explanation of whether the number is optional or required,
and the consequences of refusing to give your number, you'll be able to
decide for yourself whether to fill in the number.

There are several kinds of governmental organizations (see the list in 
the "Short History" section below) that usually have 
authority to request your number, but they are all required to provide 
the Privacy Act Statement described above.  The only time you should be 
willing to give your number with reading that notice is when the 
organization you are dealing with is not a part of the government.

             Why You May Want to 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

Here are some suggestions for negotiating with people who don't want to
give you what you want.  They work whether the problem has to do with
SSNs (your number is added to a database without your consent, someone
refuses to give you service without getting your number, etc.) or is any
other problem with a clerk or bureaucrat who doesn't want to do things
any way other than what works for 99% of the people they see.
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.  The people in the personnel and benefits
        departments often carry a lot of weight when dealing with health
        insurance companies.

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.


	How To Find Out If Someone Is Using Your Number

There are two good places to look to find out if someone else is using 
your number: the Social Security Administration's (SSA) database, and 
your credit report.  If anyone else used your number when applying for a 
job, their earnings will appear under your name in the SSA's files.  If 
someone uses your SSN (or name and address) to apply for credit, it will 
show up in the files of the big three credit reporting agencies.

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.) 
The forms are available online at the SSA's website: 
http://www.ssa.gov/online/forms.html.  You can also pick up a copy at any 
office of the SSA. 

Information about the credit reporting agencies is available in the Junk 
Mail FAQ, and various other privacy-related FAQs.  Try looking at 
http://www.cpsr.org/dox/program/privacy/privacy.html


           Choosing A Key For New Databases

Most organizations that have studied the issue have concluded that a
simple combination of Name, Address, and Phone number is usually
sufficient.  In cases where you are likely to be dealing with several
members of the same family (and thus Jr. and Sr. might have matching
records, you can add Date of Birth.  If the database saves an old 
address and the date of the move, that will usually be sufficient to 
identify particular clients uniquely.

If you're designing a database or have an existing one that currently uses
SSNs and want to use numbers other than SSNs, it's useful to have the
identifiers use some pattern other than 9 digits.  You can make them longer
or shorter than that, or include letters.  That way it won't be mistaken 
for an SSN.

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 (though the SSA will now assign a number to a legal immigrant
without connecting that to the authority to work), 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.


                            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.


                Dealing with Government Organizations

Surprisingly enough, government agencies are reasonably easy to deal with; 
private organizations are much more troublesome.  Few agencies are allowed 
to request the number, and all agences are required to give a disclosure 
complete enough that you can find the law that empowers them.  There are no 
comparable Federal laws either restricting the uses non-government 
organizations can make of the SSN, or compelling them to tell you anything 
about their plans. 

Some states have recently enacted regulations on collection of SSNs by 
private entities.  (Usually in cases of consumers making payments with 
checks or credit cards.)  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 
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

I've received several reports that a new version of the passport 
application fixes the problems described below.  Apparently, these new 
applications ask for SSN, but state that failure to provide it isn't
grounds to deny a passport.  It warns that the SSN is used to verify the 
other information on the form, and processing of the application may be 
delayed if the number is not provided.  I just went to my local Post 
Office, and found the old form still there.

Some forms for applying for US Passports (DSP-11 12/87) request a
Social Security Number, but don't give enough information in their
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
ftp://ftp.cpsr.org/cpsr/privacy/ssn/passport.ps.Z.  Other readers have
also used this technique successfully.

 Requirement for Disclosing SSNs of Minors Covered by Company Health 
 Plans Quietly Dropped

The Omnibus Budget Reconciliation Act of 1993 required all employers to
collect social security numbers for everyone covered by their health plans,
including all dependents.  The latest word is that this database has been
quietly dropped, though it may still be in the law.  If your employer
requests your children's SSNs, ask for a copy of the regulation they're
responding to.

 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.  Notice that the instructions
for form 1040 report that the fine is $50.  I have heard reports from several
people who haven't given any SSN for their children, and have paid no fine,
and I haven't heard from any one who has had to pay a fine.


                           Private Organizations

The guidelines for dealing with non-governmental institutions are much more
tenuous than those for government departments.  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.

At one point I needed a security badge from a company that wasn't my
employer (my employer was contracting to the host.)  The host company
used SSNs to do background checks on applicants for security
badges.  I asked if there was a way I could keep my SSN out of their
database, and we worked things out so I gave my number directly to the
person who ran the background check, and he used it for that and then
destroyed it.  I may have been the only person working at this very large
company who didn't have an SSN on file.

    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 suggestions above 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 will refuse to
open safe deposit boxes without a SSN, though there is no direct governmental
requirement that they collect it.

Many banks send the names, addresses, and SSNs of people whose accounts
have been closed for cause to a company called ChexSystem.  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
a bank is required to let you know if it refuses to open an account and a
report from ChexSystems was a factor.  You can also send a letter to
ChexSystems directly (Consumer Relations, 12005 Ford Road, Suite 650,
Dallas, TX, 75234) 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, 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.
Every financial institution I have asked has been willing to use a
password I supplied.  I don't know why they don't advertise this rather
than relying on the SSN.

When buying (or refinancing) a house, you have to give your SSN, 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 wants 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,
especially since 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
group's health plan.  In the latter case, you have to get your employer
to make an exception to their standard practices.  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.

Insurance companies often require the SSN for underwriting purposes, but
don't usually use it for underwriting personal property or personal
auto insurance policies.  You may be able to get them to leave the number
out of their data base, even if they want to use it when
deciding whether to cover you.  They may call every few years to ask
for it again.

Insurance companies share information with one another that they have
collected while evaluating applications for life, health, or disability
insurance.  They do this by sending the information to an organization
called the Medical Information Bureau.  The information they share
includes test results and brief descriptions of conditions relevant to
health or longevity.  MIB rules prohibit the reporting of claims
information.  The MIB doesn't use the SSN as an identifier in their
files, and doesn't report SSNs when providing reports.  You can get a
copy of your MIB file by writing to Medical Information Bureau, P.O. Box
105, Essex Station, Boston, MA 02112.  Their phone number is (617)426-3660.

 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.


	Using a False Social Security Number


If someone absolutely insists on getting your Social Security Number, you 
may want to give a fake number.  I have never needed to give a fake 
number; at least one of the remedies described above has always 
worked for me.  There *are* legal penalties for providing a false number 
when you expect to gain some benefit from it.  For example, a federal 
court of appeals ruled that using a false SSN to get a Driver's License 
violates federal law. 

Making a 9-digit number 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.  There were at least 40 different people in
the Selective Service database at one point who gave this number as their
SSN.  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.html.

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.



                       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.


    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)
http://www.cpsr.org/cpsr/privacy/ssn/ssn.faq.html.  The HTML
version of the SSN FAQ stored there contains several resources which I
haven't included in the plain text version.

rtfm.mit.edu is a standard archive which has many other FAQs.

    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.

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.

other Privacy-related Resources
    http://www.cpsr.org/dox/program/privacy/privacy.html



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

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