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GAO Report Concludes Many Public Records Contain SSNs

A recent report by the U.S. Government Accountability Office is further evidence of the growing concern about the over-use of Social Security Numbers (SSNs) and the potential for their misuse as part of the growing problem of Identity Theft.  The November 2004 report entitled “Governments Could Do More to Reduce Display in Public Records and on Identity Cards” was prepared at the request of Rep. E. Clay Shaw, Jr. (R-Fla.) who is the author of a bill that would impose new restrictions on the use of SSNs, including banning their display on government ID cards.

As Chairman of the House Ways and Means Subcommittee on Social Security, Rep. Shaw has declared that “Social Security is my highest priority”.  He introduced the “Social Security Number Privacy and Identity Theft Prevention Act of 2003” in the 107th Congress (H.R. 2036), and a similar bill was introduced and approved by Ways and Means during the 106th Congress (H.R 4857).  He has held hearings on the “Use and Misuse of Social Security Numbers” ) and maintains a web site with resources on Protecting the Privacy of Social Security Numbers.

The recent GAO study was conducted to focus on government uses of SSNs, including:

  • The extent to which SSNs are visible in records made available to the public,
  • The reasons for which governments collect SSNs in records that display them to the public, and
  • The formats in which these records are stored and ways that the public gains access to them.

The report concluded that the exposure of SSNs to public view is particularly troublesome at the state and local government levels of government.  “SSNs are most often to be found in state and local court records and in local property ownership records,” said the report. The report continued:

. . . Various state and local officials commonly reported needing them for identity verification.  A few, however, said they had no use for the SSN, but that documents submitted to their offices often contained them.  States also commonly reported using the SSN to facilitate the matching of information from one record to another.

The report also found that SSNs are “stored in a multiplicity of formats” but that public access is usually limited to “the inspection of individual paper copies”.  The good news for privacy advocates is that few state agencies make records with SSNs available on the Internet.  The bad news is that 15-28 percent of the nation’s 3,141counties place them on the Internet.

The report also focused on the potential exposure of SSNs resulting from their display on ID cards.  The GAO found SSNs are displayed on:

  • 42 million Medicare cards,
  • 8 million Department of Defense identification cards, as well as some insurance cards, and
  • 7 million Veterans Affairs identification cards

Therefore, the GAO has recommended that “the Office of Management and Budget identity those federal activities that require or engage in the display of SSNs on health insurance, identification, or any other cards issued to federal government personnel or program beneficiaries, and devise a governmentwide policy to ensure a consistent approach to this type of display.”

Although this report and the corresponding legislation is focused on the federal government, I think there are significant implications for colleges and universities of the overall trend to limit the use of SSNs except for required purposes.  First, the prohibition against the printing of SSNs on ID cards or other documents (e.g., health insurance forms, library records, payroll checks, and other reimbursements) is already becoming the policy of many state governments.  For public colleges and universities, the restrictions on use of SSN will clearly apply to them.  Second, I think it will be a race to see if an outright ban on use of SSNs as primary identifiers for student and employee IDs will happen first at the state level or federal level.  We are already seeing evidence that state governments are moving in that direction.  Therefore, it is inevitable, in my opinion, that colleges and universities will need to limit their use of SSNs on campus.  In which case, it is probably not too early to start the planning process.  To that end, we have compiled a list of resources on “Eliminating the Use of Social Security Numbers as Primary Identifiers.”

For more information, see the Washington Post story on “GAO:  Social Security Numbers Vulnerable” (November 12, 2004, A23).

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