The Social Insurance Number (SIN) Code of Practice
On this page
- List of abbreviations
- Section 1 – Introduction
- Section 2 – Information for SIN holders
- Section 3 – Information for employers
- Section 4 – Information for private sector organizations
- Section 5 – Information for Service Canada and Service Canada’s partners
- Section 6 – Service Canada employees’ duties
- Annex 1: Authorized federal uses of the SIN
- Annex 2: SIN holder dos and don’ts: protecting your SIN
- Annex 3: What to do if you suspect your SIN is compromised
- Annex 4: What to do if your organization is handling privacy breaches involving SINs
- Annex 5: Employers’ dos and don’ts: requesting, collecting, using and storing the SIN
- Annex 6: Private sector dos and don’ts: requesting, collecting, using and storing the SIN
List of abbreviations
- Canada Employment Insurance Commission
- Canada Pension Plan
- Canada Revenue Agency
- Chief Privacy Officer
- Department of Employment and Social Development Act
- Employment and Social Development Canada
- Employment Insurance
- Immigration, Refugees and Citizenship Canada
- Integrity Services Branch
- Personal Information Protection and Electronic Documents Act
- Québec Parental Insurance Plan
- Québec Pension Plan
- Social Insurance Number
- Social Insurance Register
- Treasury Board Secretariat
Section 1 – Introduction
In this section
The SIN Code of Practice states the roles and duties of SIN users. SIN users include:
- private sector and not-for-profit organizations
- Service Canada and its federal and provincial government partners
- Service Canada employees
The purpose of the Code of Practice is to:
- establish a set of principles (addressing privacy, security and integrity) for the management and use of the SIN
- increase awareness about the shared duty to protect the SIN from inappropriate use and fraud
- provide standards, which follow legislation, policy and directives, to help all SIN users understand and fulfil their duties
The Code of Practice respects and explains relevant laws, policies and directives. Some examples are:
- Department of Employment and Social Development Act (DESDA)
- Employment Insurance Act
- Privacy Act
- Personal Information Protection and Electronic Documents Act (PIPEDA)
- Policy on Privacy Protection
- Directive of Social Insurance Number
These documents govern the use of the SIN. More than 150 provincial and territorial acts mention SIN use in their texts. Consult your provincial or territorial government for more information about SIN requirements in your jurisdiction. Those using SINs must uphold these laws and policies based on their jurisdiction. Jurisdictions include the federal or provincial level and the private sector.
The SIN program began in 1964 to register people for Unemployment Insurance. Unemployment Insurance later became Employment Insurance (EI). In 1965, the Canada Pension Plan (CPP) and the Quebec Pension Plan (QPP) began to use the SIN as a file number. In 1967, the SIN also became a file number for income tax.
DESDA defines the SIN as a 9-digit number for use as a file number, account number or data processing purposes. No one should use it as an identity document or a piece of identification. People use the SIN to be able to work in insurable or pensionable employment and to file income tax returns. The SIN also plays a role in managing government SIN-enabled programs and services.
Many people need a SIN to work in Canada. Many also need a SIN to receive benefits and services from government programs.
At Service Canada, we issue a SIN to a person for life. No one may use another person’s SIN as if it is their own. Safeguarding the privacy, security and integrity of the SIN is very important to help protect people, organizations, and the government against fraud and misuse.
The Government of Canada stopped producing physical SIN cards after March 31, 2014. Instead, the Government of Canada now produces a letter that confirms a client’s SIN. Clients receive this letter either in person or by mail.
1.2 Service Canada’s message about data breaches and SIN fraud
The SIN Code of Practice outlines the shared duty to maintain the security and integrity of the SIN. It also describes how to prevent fraud and protect against potential data breaches.
At Service Canada, we commit to helping fraud victims. This Code of Practice is one of Service Canada’s supports available to fraud victims as well as other important information for all SIN users.
DESDA prohibits creating, using, buying and selling, and making available personal data that isn’t your own. This includes the SIN. The SIN program does not proactively issue new SINs. Subsection 28.2(8) of DESDA limits issuing new SIN to specific cases. These include cases where there is proof of misuse of the SIN (for example, to get credit or services). It also includes cases where the person requests a new SIN.
Getting a new SIN won’t protect a person from fraud or theft. The previous SIN would continue to exist and be linked to the person in the private sector. To update their files, the owner of a new SIN must contact:
- their financial institutions
- pension providers
- other government entities
- employers (past and current)
A client who gets a new SIN needs to track their accounts and credit reports for both SINs on a regular basis. Government of Canada programs, departments and agencies may still have the client’s old SIN on file. It is the client’s duty to contact those government programs, departments and agencies to update their file. This way, these programs, departments, and agencies can link the client’s new SIN to their benefit(s) account(s).
Section 2 – Information for SIN holders
In this section
- 2.1 Key duties of SIN holders
- 2.2 The SIN and you
- 2.3 Service Canada’s pledge to SIN holders
Department of Employment and Social Development Act (DESDA) and the Employment Insurance Act specify who needs a Social Insurance Number (SIN) to work in Canada. This list includes:
- Canadian citizens
- permanent residents
- temporary residents
These individuals also need a SIN to receive benefits and services from government programs.
The Employment Insurance Regulations require an individual to apply for a SIN as soon as possible. You must provide your SIN to your employer no later than 3 days after your employment start date. This does not prevent you from working before receiving your SIN.
If you don't already have a SIN, you must apply for one within 3 days after you start your employment. You must also provide proof to your employer that you have applied.
Under the Income Tax Act, you need a SIN:
- to complete your income tax return
- when applying for Employment Insurance (EI)
- when applying for Canada Pension Plan and applying for Quebec Pension Plan (CPP/QPP) benefits
Certain private sector entities must ask for your SIN. They do this for any accounts and investments that pay income (such as interest and dividends). This includes:
- credit unions
- trust companies
Your SIN is confidential. Your SIN card or confirmation letter isn’t an identity document. It is not a piece of identification. DESDA defines the SIN as a 9-digit number for use as a file number, account number or data processing purposes.
Except for specific government programs, you have a choice about the collection and use of your SIN. You should provide it only when the law requires it. This helps to prevent fraud and to ensure that your personal information remains private. If you share it outside of the uses prescribed by law, you must accept the risk of doing so.
It is not against the law to ask for an individual’s SIN. Many private sector organizations do ask for your SIN. This is part of their policies and procedures. But, at Service Canada, we discourage such practices.
Some private sector organizations will ask for your SIN when checking your credit rating. This is to increase the probability that they’re checking or updating the right credit records. When asked for your SIN for a credit check, you should instead provide the requestor with a copy of your credit report. This credit report should not include your SIN.
Remember: The law does not allow private sector businesses to require clients’ SIN for purposes other than income reporting. No one can deny you a product or service for refusing to provide your SIN when the law does not require it.
To inform yourself further on this subject, please refer to: Protecting your Social Insurance Number.
2.1 Key duties of SIN holders
As a SIN holder, you have 4 key duties to protect your SIN.
1. Never give out your SIN unless you're sure the law requires it or unless you're satisfied it’s necessary and you understand the risks
You must provide your SIN to take part in some government programs and services. To inform yourself about federal legislation and the use of SINs, refer to Annex 1, Authorized federal uses of the SIN.
In the private sector, you must provide your SIN to your employer for income tax and benefit purposes. In some cases, you must give your SIN to certain private sector entities. Except when required by law, it is your decision when to share your SIN information and with whom.
You can share your SIN outside of legally prescribed uses. However, in doing so, you may expose yourself to a heightened risk of fraud or identity theft. You should only do so if you are willing to assume that risk.
Someone may ask you to provide your SIN for the following purposes, but you're not required by law to provide it when:
- proving your identity
- completing an employment application (before you get a job offer)
- applying to rent a property
- applying for credit products (such as a credit card, loan or mortgage) with a financial institution to allow for a credit rating check
- cashing a cheque or transferring money
- applying for a membership
- completing some banking transactions (mortgages, lines of credit, loans)
- completing medical questionnaires
- renting a motorized-vehicle or equipment
- subscribing to cellular telephone, internet or television services
- writing a will
- negotiating a lease with a landlord
- applying to a university or college
- registering for supplemental health offered by your employer
- communicating electronically, particularly online
No one can deny you a product or service for refusing to provide your SIN when it’s not required by law. If the organization refuses to give you the product or service unless you give your SIN, you may file a complaint. You can also call toll-free at 1-866-274-6627, or find a Service Canada office to visit in person.
2. Take steps to protect your SIN from theft and misuse
The Privacy Act defines the SIN as personal information and as such, all SIN users should work to protect it. If someone steals your SIN, they could use it to gain access to a wide range of personal information. They could also use it to gain access to benefits and services in your name. As a SIN holder, you have key duties about the protection of your SIN. Follow Annex 2, SIN holder: dos and don’ts to protect yourself and your SIN.
Act if you think that a private organization isn’t safeguarding your personal information or your SIN properly. Speak to the person in charge if an organization refuses to provide the product or service that you requested unless you disclose your SIN. You may also use the organization’s complaint process. Many organizations aren’t aware of the appropriate uses of the SIN. Once informed, they may willingly change their practices.
If you're not satisfied with the organization’s response or suspect that the organization isn’t a good steward of your personal information:
- contact the organization’s industry association, ombudsman or complaint office, or
- call 1-800-282-1376 to make a formal complaint against the organization to the Office of the Privacy Commissioner of Canada
3. Inform Service Canada and other appropriate authorities if you believe any actor is using your SIN in a fraudulent way
Criminals may use stolen or lost SINs to defraud governments, organizations, and individuals. If someone else uses your SIN to work illegally or to get credit, governments may tax you for income you didn’t earn. You may also have difficulty when you apply for credit. Even if you take steps to safeguard your personal information, you could still be a victim of identity theft. Thieves are becoming more creative in their attempts to steal personal information. If you suspect that someone is using your SIN fraudulently, it is important to act fast. Annex 3, What to do if you suspect your SIN is compromised, instructs you on steps to take and relevant contact information.
4. Contact Service Canada
You should contact Service Canada when:
- you legally change your name
- your citizenship status changes
- your temporary SIN expires
- you'd like to update your gender designation
- you have proof that someone is using your SIN in a fraudulent way
- you discover that information on your SIN record is incorrect or incomplete
You can update your Social Insurance Register (SIR) record.
For more information on what you need to apply, visit the apply to update your SIR record page. You can also call toll-free 1-866-274-6627. Agents are available Monday to Friday from 8:30 am to 4:30 pm (your local time), except statutory holidays. If you’re calling from outside Canada, the number is: 1-506-548-7961, Monday to Friday from 8:30 am to 8:30 pm. Long distance charges apply.
2.2 The SIN and you
The SIN is personal information under the Privacy Act. You can protect your own privacy by keeping control of your personal information and treating the SIN as confidential. The Personal Information Protection and Electronic Documents Act (PIPEDA) is the federal privacy law for private sector organizations. PIPEDA protects your right to privacy.
PIPEDA requires private sector organizations to follow rules for the collection, use and disclosure of personal data. These rules include putting safeguards in place to protect your personal data. They protect your personal data against loss, theft or unauthorized disclosure.
According to PIPEDA, you have the right to:
- know why an organization collects, uses or discloses your personal information
- expect an organization to collect, use or disclose your personal information appropriately
- expect an organization to only use information for purposes that you agreed to
- know who in the organization is in charge of protecting your personal information
- expect an organization to protect your personal information by taking the proper security measures
- expect the personal information an organization holds about you to be accurate, complete and up-to-date
- access your personal information and request changes
- complain about how an organization handles your personal information
For more information on how PIPEDA applies to the use of the SIN, please visit the Office of the Privacy Commissioner’s website.
If you have forgotten your SIN, you can find your SIN on your income tax return. You may also request a confirmation of your SIN online or by mail. You may also find a Service Canada office and request one in person. For more information on how to request a confirmation of your SIN, visit the how to apply for a SIN website.
Your employer uses your SIN to inform the government. This includes information about your income and the amount of income tax deducted. It also includes the amounts withheld for government benefit programs and services (such as EI, CPP/QPP, Records of Employment and T4).
Providing your SIN to your employer helps to ensure that your taxable income and pension contributions are accurate. For example, an employer will collect an employee’s SIN. This is to provide the employee with various year-end reporting slips.
At Service Canada, we'll never call or email you and ask for your SIN and/or credit card number. Someone may reach you by telephone, text, mail or email who claims to be from the Government of Canada (Service Canada). They may request your SIN, or credit card, bank account and passport numbers. These communications may even say that they need this information so that you can receive a refund or payment. These are fraudulent communications.
Another common fraud tactic is to refer clients to a website that looks like the Service Canada website. The website may ask you to verify your identity by entering personal information. You should not respond to such communications.
If you receive a communication that appears to come from or be like a Service Canada program, we encourage you to check our website. You can also contact our Social Insurance Registration Office. If you responded to what may resemble a misleading or fraudulent communication, please contact the Royal Canadian Mounted Police's Canadian Anti-Fraud Centre. You can do so by email at firstname.lastname@example.org or by calling 1-888-495-8501. You may also contact the Competition Bureau for help. You can reach them through their website or by calling 1-800-348-5358.
For more information, visit Service Canada’s Unauthorized/Misleading Communications website.
2.3 Service Canada’s commitment to SIN holders
At Service Canada, we have the duty to protect a person’s SIN from inappropriate use, fraud and theft within federal government benefits and programs. We take this duty very seriously and have many ways of safeguarding SINs. We also ensure the accuracy of information in the SIR. This includes well-defined and functioning practices that detect and protect against improper access to personal information.
At Service Canada, we:
- monitor and restrict access to your SIN and personal information
- allow access only to authorized individuals and organizations with a “need to know”
- carefully check that the identity of SIN holders and applicants is correct to maintain the accuracy and completeness of personal information
- inform SIN holders about the proper protection, use and disclosure of the SIN
- assist all clients wanting information about the SIN or government services related to it
Section 5, Service Canada and its Partners’ Responsibilities describes Service Canada and our partners’ roles and duties related to the SIN.
Section 3 – Information for employers
In this section
- 3.1 Key duties of employers
- 3.2 Information about the use of the SIN and employers
- 3.3 Service Canada’s commitment to employers
As an employer, you must request the Social Insurance Number (SIN) of each employee you hire. This is to provide the employees with Records of Employment. This is also to provide them with various year-end reporting slips. Such slips include, for example, the T4 for income tax purposes. You also use SINs to record and forward employee payroll deductions for:
- income tax
- Employment Insurance (EI) program
- Canada Pension Plan (CPP) or Québec Pension Plan (QPP), and
- Quebec Parental Insurance Plan (QPIP)
3.1 Key duties of employers
As an employer, you play a vital role in protecting the SIN from misuse, fraud, and theft. You must ensure that you identify employees correctly. You must request other pieces of identification before finalizing their employment documents. A SIN card or SIN confirmation letter is not an identity document or a piece of identification. Employees cannot use these documents for this purpose.
Private sector employers may also have specific roles and duties for the SIN and for personal information. Inform yourself further about private sector duties in Section 4, Information for Private Sector Organizations.
Key duties for employers are:
- by law, you must request each new employee’s SIN no more than 3 days after the day employment begins
- you must ensure that employees with a SIN beginning with the number "9" have authorization to work in Canada. They must have valid immigration documents
- employers must protect their employees’ personal information, including SINs, from theft and misuse
- employers must inform Service Canada if they suspect a SIN is being misused
1. By law, you must request each new employee’s SIN no more than 3 days after the day employment begins
If your employee does not already have a SIN, you should tell them to apply for one. They can do so online, by mail or by visiting the Service Canada Centre closest to them. The employee must apply for a SIN and provide proof to you that they have applied. You must request this information soon after the employment start date. They must also inform you of their SIN within 3 days of getting the SIN confirmation letter.
To confirm the SIN of a current or former employee, contact our Social Insurance Registration Office. You can reach the Office at 1-866-274-6627. If you’re outside of Canada, call 1-506-548-7961 (long distance charges apply). We’ll need your Canada Revenue Agency (CRA) issued business number. You must also provide correct information to authenticate the company and the SIN holder. This may include:
- date of birth
2. You must ensure that employees with a SIN beginning with the number "9" have authorization to work in Canada
Immigration, Refugees and Citizenship Canada (IRCC) approves temporary residents to work in Canada. These residents are neither Canadian citizens nor permanent residents and receive SINs that begin with the number "9."
These SINs are valid based on IRCC’s work permits. They correspond to the date the foreign worker may work in Canada. The SIN alone does not allow them to work. You must verify all terms and conditions on the work permit before hiring them. This includes authorized dates and work locations.
If the immigration document of a foreign worker expires, you must ask the employee to get a valid document before hiring them. You must ask the employee to contact IRCC to do so. You must also inform the employee to apply with the new immigration document to us at Service Canada. This is to update the SIN record with the new expiry date.
A temporary resident is able to work while the decision on their work or study permit renewal is pending. They can work even if their permit expires before they receive the decision. In these situations, temporary residents can continue working, studying or using their SIN under the same conditions as long as they remain in Canada. This is according to paragraph 186(u) and section 189 of the Immigration and Refugee Protection Regulations.
These conditions remain valid until IRCC decides about renewing their work or study permit. The temporary resident then has “implied status”. You, as the employer, must verify the new immigration document once you get it. You must verify that IRCC’s decision allows the employee to continue working in Canada. You must also verify the new expiry date. You must inform the employee to apply with the new immigration document. This is to update their SIN record with the new expiry date.
For more information, visit the IRCC website. You may also call the IRCC Call Centre at 1-888-242-2100 or TTY: 1-888-576-8502.
3. Employers must protect their employees’ personal information, including SINs, from theft and misuse
Employers like you, should store and dispose of employees’ personal information safely and securely. Only authorized persons may access this information. Employers like you, who have to withhold or deduct CPP contributions, EI premiums and taxes, must keep records. You must keep these records for at least 6 years from the end of the last year that you employed the person. This is according to the Employment Insurance Act, the Canada Pension Plan Act and the Income Tax Act.
The Personal Information Protection and Electronic Documents Act (PIPEDA) is the federal privacy law for private sector organizations. This includes private sector employers. PIPEDA requires private organizations to follow policies when collecting, using, or disclosing personal data in their commercial work. Personal data may include the SIN.
These policies include putting in place security safeguards. You should follow Annex 5, Employers dos and don’ts: Requesting, collecting, using and storing the SIN.
If someone steals, uses, or discloses employees’ SINs in a fraudulent way, you must act quickly. See Annex 4, What to do if your organization is handling privacy breaches involving SINs.
4. Employers must inform Service Canada if they suspect a SIN is being misused
You play a leading role in detecting and preventing fraud relating to SINs. Illegal employment and income tax evasion are 2 of the main motives for SIN fraud. Every year, criminals and other actors use stolen, lost, borrowed, and fake SIN cards or confirmation letters. Fraudsters use them to defraud individuals, private sector organizations and governments.
If you suspect a SIN is compromised or being used for fraud, you must immediately report the issue. You should contact our Social Insurance Registration Office at 1-866-274-6627. You must provide us at Service Canada with your CRA-issued business number. You must also provide information to authenticate the company and the SIN holder.
Agents are able to help Monday to Friday from 8:30 am to 4:30 pm (your local time), except public holidays. If you're calling from outside Canada, the number is: 1-506-548-7961. You can reach agents Monday to Friday from 8:30 am to 8:30 pm (Atlantic time). Long distance charges apply.
3.2 Information about the use of the SIN and employers
Your employees don't need to show you physical proof of their SIN. They don't need to provide their SIN card or confirmation letter to you.
Only employers may verify an employee’s SIN from the Social Insurance Registration Office. Payroll service providers cannot contact us to verify a SIN as they are not the employer. Still, payroll service providers must receive the employees’ SINs. This is to fulfil their roles and duties to their client or the employer.
There should be a contractual agreement between the payroll service provider and the employer to explain this need. These agencies must adhere to this Code of Practice.
Many people use a nickname, middle name or another name. You must ensure that you identify your employees correctly. You should record your employee’s legal name. You may remind employees that their SIN record should reflect their current legal name.
If someone’s name changes and this person has a SIN, they must get their SIN updated. This is regardless of the reason for name change (because of marriage or otherwise). The person must apply to update their SIN record under the new name within 60 days.
You should not use the SIN as an employee identifier. Serious problems could arise if the employee’s personal information is at risk. We strongly encourage you to use another method of employee identification. This is to protect your employees’ privacy and maintain the integrity of the SIN.
3.3 Service Canada’s commitment to employers
Identity fraud, including stolen, lost, and borrowed SINs, can lead to increased costs. These costs can harm individuals, private sector organizations and governments. Safeguarding the SIN is key to the management and delivery of many government services and benefit programs. You can help prevent SIN fraud and misuse.
Keep unauthorized persons from accessing employee files containing the SIN. You can also report suspected SIN misuse. Everyone should do their part to ensure their personal information is accurate and complete. Here at Service Canada we take this duty very seriously. We’ve many ways of keeping SINs and the accuracy of personal information secure.
To fulfil this duty to employers, we commit to:
- confirming and/or providing the SIN of their employees
- offering guidance, information and tools to help employers fulfill their SIN duties
- assisting employers when SIN information in their care is put at risk
- working with employers to detect, report and inquire into suspected misuse of a SIN
For a full description of our roles and duties related to the SIN, refer to Section 5, Service Canada and its Partners’ Responsibilities.
Section 4 – Information for private sector organizations
In this section
- 4.1 Key duties of private sector organizations
- 4.2 Information about the use of the SIN in the private sector
- 4.3 Service Canada’s commitment to private sector organizations
In certain cases, private sector organizations may collect the Social Insurance Number (SIN). These include employment and income tax purposes. These also include for government benefit payments, and other government programs.
Organizations like yours may choose to use the SIN for other reasons as well, like credit rating and identification. Here at Service Canada, we discourage using the SIN for these purposes. This Auditor General’s report on the SIN suggests that these practices endanger the integrity of the SIN. This has increased the risk of SIN fraud and abuse.
The Office of the Privacy Commissioner of Canada recommends that organizations refrain from requesting their clients’ SIN when the law does not require it. Clients should not provide their SIN unless the law requires it. For more information, please visit the Office of the Privacy Commissioner's website.
Remember: Your private sector organization does not have the legal authority to request clients’ SINs for any reason, except to report income. You cannot deny a client a product or service if they refuse to provide their SIN when the law does not require it.
4.1 Key duties of private sector organizations
The Personal Information Protection and Electronic Documents Act (PIPEDA) describes the SIN as personal information. PIPEDA balances a person’s right to privacy with an organization’s need to collect, use or disclose personal information. PIPEDA is the federal privacy law for private sector organizations. PIPEDA requires private sector organizations to follow rules for the collection, use and disclosure of personal data (including SINs) during business ventures.
These rules include putting in place security safeguards to protect personal data against loss, theft or unauthorized disclosures. Innovation, Science and Economic Development Canada has overall policy management for PIPEDA. This includes recent amendments introduced in 2018.
A private sector organization like yours has 4 key duties to protect the SIN, which respect the principles of PIPEDA.
1. A private sector organization should never use the SIN as a piece of identification or as a client identification number
The SIN is not an identity document or a piece of identification and no one should use it for that purpose. As such, no one should view it as official government identification. Instead, to verify a client’s identity, request an appropriate piece of identification that includes specific data elements. Specific data elements may include:
- a name
- a date of birth
- a place of residence
You should never ask for a client’s SIN unless there is a legal need to collect it. If your private sector organization collects the client’s SIN, you must follow PIPEDA, or applicable provincial legislation. This includes disclosing the purpose for using the SIN and getting consent. You must only use the SIN for the disclosed purposes.
If your private organization needs to assign a client identification number to its clients, you should create one of your own.
2. If you request a client’s SIN, you must then tell them why you’re requesting it and you must only use it for that purpose
There is only 1 reason a private sector organization legally needs the SIN from clients. Banks, credit unions and trust companies need your SIN for accounts and investments that pay income (such as interest and dividends). For example, financial institutions need the SIN to report the interest earned in a person’s bank account. If an account does not produce income, the law does not require your organization to ask for the client’s SIN.
The law, in turn, doesn’t require the client to provide their SIN. You should tell your client that in these cases, the SIN is optional. You should state that the law requires the SIN when your organization uses it to report the interest earned in a person’s bank account.
3. A private sector organization cannot make clients provide their SIN without a legal need
You should inform your clients about this. You must receive a client’s consent to collect and use their SIN. If the law does not require providing a SIN, you should offer the client a way to withdraw consent. This option should be available at any time after the client provides their SIN to you. The ability to withdraw consent should be clear, easy to execute, secure and effective.
4. Private sector organizations must protect their clients’ personal information (including the SIN) from theft and inappropriate use or disclosure
If you receive your clients’ personal information, you must protect it. You must ensure the information is safe and secure from theft, inappropriate use or disclosure. Your organization should keep SINs under lock and key when they’re stored in hard-copy format. You should encrypt of password protect SINs stored in a digital format. You should also keep SINs stored away from other personal information.
Private sector organizations should follow Annex 6, Private sector dos and don’ts: Requesting, collecting, using and storing the SIN.
If someone steals or inappropriately uses your clients’ SINs, you must act. See Annex 4, What to do if your organization is handling privacy breaches involving SINs.
4.2 Information about the use of the SIN in the private sector
At Service Canada, we strongly advise against private organizations requesting the SIN as identification. This is because:
- the SIN has no security features to identify the person
- the private sector is unable to verify the information in the SIR
- there is an increased risk for private sector entities that solely use the SIN for identification
- this practice may also increase the chances that identity thieves will target the organization
If your organization still wishes to request SINs for identification purposes only, you must not suggest in any way that you require SINs. You cannot require a SIN to establish a business relationship. You must make it clear that the SIN is optional and provide the client with other options.
Before providing their SIN, clients have the right to ask what the legal requirements are for the SIN. More information is available about the SIN on the SIN overview page. You can also call toll-free at 1-866-274-6627, or visit a Service Canada Centre near you.
There is no longer a legal need to provide physical proof of the SIN (card or confirmation letter). Private sector organizations do not need to request a proof of a client’s SIN.
You should pursue a policy of openness with your clients. You should readily disclose personal records to the client to whom they belong. Clients have the right to know what is in these records. For more information on PIPEDA’s Openness Principle, please visit the website of the Office of the Privacy Commissioner.
Before PIPEDA, private sector organizations collected clients’ SINs when the law didn’t require that you needed consent to do so. The provisions of PIPEDA apply to all personal information held by an organization. This is the case regardless of when the organization collected the information. In some cases, destroying or erasing older files may be the best way to deal with this information. Still, organizations like yours don’t always need to seek consent to continue holding and using SINs on file.
To decide if you should keep a client’s SIN, ask the following question: Is there a legal or contractual need to keep the information? If the answer is yes, then consider the following questions.
- Is the information still serving (or has it ever served) a useful or necessary purpose?
- Is it likely the client would expect the organization to keep the SIN on file?
If the answer to these questions is ‘no’, it is best to dispose of these SINs in a safe and secure manner.
4.3 Service Canada’s commitment to private sector organizations
At Service Canada, we commit to offering guidance, information, education and tools to organizations. This is to help organizations like yours to fulfil their duties of safeguarding the SIN.
For a full description of Service Canada’s roles and duties related to the SIN, refer to Section 5, Service Canada and its Partners’ Responsibilities.
Section 5 – Information for Service Canada and Service Canada’s partners
In this section
- 5.1 Key duties of Service Canada and other authorized departments and agencies
- 5.2 Sharing SIN information, Service Canada and other authorized departments and agencies
- 5.3 Service Canada’s commitment to other authorized departments and agencies
The Canada Employment Insurance Commission (CEIC) has the authority to assign Social Insurance Numbers (SINs). The Department of Employment and Social Development Act (DESDA) and the Social Insurance Number Regulations give the CEIC these rights. The CEIC also has the authority to maintain the Social Insurance Register (SIR).
The CEIC has assigned the duty of issuing and administering SINs to the Integrity Services Branch (ISB). The ISB is within the department of Employment and Social Development Canada (ESDC)/Service Canada.
Here at Service Canada, we’re in charge of:
- developing SIN operational policies and directives
- administering the registration of SIN applicants and maintaining the SIR
- handling requests for access to SIN information
- developing and implementing investigation and control measures to detect and deter abuse of the SIN
- working on communication strategies with companies and the general public
- reviewing legislation related to the SIN
The Treasury Board Secretariat (TBS) and Service Canada, on behalf of the Commission, are both in charge of policy on uses of the SIN. TBS maintains the Directive on Social Insurance Number, which directs government departments and agencies on collecting and using the SIN. We maintain the SIN Code of Practice.
We work with a wide array of organizations to deliver the SIN program. Service Canada and our partners, like you, commit to using the SIN correctly. We also make sure that measures exist to protect the privacy of individuals in program delivery.
Service Canada's SIN partners are federal and provincial government organizations that formally agree to share or access information held in the Register.
5.1 Key duties of Service Canada and other authorized departments and agencies
Only authorized departments and agencies may get information from the SIR. The following legislation informs this SIR information sharing:
- the TBS Directive on Social Insurance Number, and/or
- a formal information sharing agreement
At Service Canada, we commit to protecting clients’ personal information. This is the same as for other authorized departments and agencies. We must also ensure that the information in the SIR is accurate, complete, and secure. To do this, us and other authorized departments and agencies have the following key duties.
1. Service Canada and other authorized departments and agencies must restrict access to and disclosure of information from the SIR
Formal agreements govern program access to information contained in the SIR including:
- what information can be accessed or disclosed
- the purpose for which and to whom the information can be accessed
- the policies and procedures
Without an agreement, entities cannot access information in the SIR. We limit SIR access to the fewest data elements required to do one’s job. This is a security best practice for protecting information. Service Canada monitors compliance to the terms of the agreement, which can be subject to audit. Service Canada and our partners must share any information using a secure method. Service Canada specifies what secure method to use.
2. Service Canada and other authorized departments and agencies must work to protect personal information from theft, inappropriate access or disclosure
Service Canada and our partners must follow all Government of Canada privacy and security legislation and policies. These include the Privacy Act and the Treasury Board Secretariat Policy on Information Management. Service Canada and our partners must also adhere to all privacy and security policies, procedures and practices related to SINs. Our various agreements specify this. Service Canada and our partners must inform employees of all policies and procedures.
Service Canada and our partners should also ensure that employees have completed all required training and have the proper security screening. We monitor who accesses SIN records via access logs. We do so to detect inappropriate or suspicious access. We can then look into and address adverse cases.
Corrective measures are in place for cases of non-compliance. These can lead to punitive measures. If a material privacy breach occurs, you must notify the proper actors. These are the Office of the Privacy Commissioner of Canada and the Treasury Board of Canada Secretariat.
3. Service Canada and other authorized departments and agencies must confirm the identity of clients
Identifying clients accurately is important. It ensures that the right client receives the right benefit or service. It is also essential to prevent fraudulent use. Service Canada and our partners must confirm a client’s identity. When doing so, we must follow agreements and Service Canada identity management policies.
These policies include:
- accepting only proof-of-identity documents that us at Service Canada approve for use
- fully reviewing a client’s SIN record by comparing the information from the SIR with their identity and program information to ensure consistency
- correcting information on someone’s SIN record if Service Canada or our partners find a discrepancy or error
- acting if the record has an annotation or a condition
Partners should consult their agreement and related procedures if the record has an annotation or condition. This is to find out what action to take. This may include a referral. This could be to National Investigative Services or to the Social Insurance Registration Office.
4. Service Canada is in charge of personal information held in the SIR and authorized departments and agencies help to maintain the accuracy and completeness of this information
Accurate and complete information in the SIR ensures that the right client receives the right benefit. It allows for fraud protection for all programs that use the SIN. Service Canada and our partners must follow Service Canada’s identity management policies.
When someone notifies a Service Canada partner of an error on their SIN record, you, the partner, must contact Service Canada. If the error is a data capture error, we will check if we can:
- correct it by phone, and
- if we can do so without contacting the client
If we cannot, the Social Insurance Registration Office will work with you, the partner, to inform the client about how to correct the data. The Office will also confirm what documentation the client will need to provide and the service options that are available to the client. This is the same approach for cases where the inaccuracy isn’t due to a data capture error.
5. Service Canada and authorized departments and agencies must establish risk-management and monitoring practices
Service Canada and partners like your department/agency must identify high-risk areas. This is to detect and prevent fraud and unauthorized access or disclosure of information from the SIR. Whenever personal information is accessed, Service Canada and partners should document it. This is to track compliance to privacy, security and program integrity policies and principles.
Service Canada and our partners must track the use of personal information. We all must also detect unauthorized access or amendments to personal information. If anyone goes against these policies and principles, we must report it to Service Canada officials. We have officials, processes and mechanisms in place that together act to investigate and limit breach/fraud events in its programs.
To inform yourself about individual employees’ duties, see Section 6, Service Canada Employees’ Responsibilities.
5.2 Sharing SIN information, Service Canada and other authorized departments and agencies
The DESDA governs the disclosure of information from the SIR. Under subsection 28.2(5) of this Act, the CEIC or its entrusted authority can grant approval to disclose SIR information to partners like you.
You cannot share information from the SIR provided to your authorized department or agency by us at Service Canada with another organization. This is the case even if that organization is an authorized user. Organizations wishing to get information from the SIR should contact the SIN program.
The SIN program verifies that the requesting party has permission to get this information. The SIN program also makes sure that the request meets the terms of the agreement. This includes the type of information that the terms of the agreement allows Service Canada to disclose, and the reason for requiring the information.
Employees of authorized organizations that request SIN information, but who don’t have access, must contact the SIN program. The employees can then get information from the Register. The employee's name must also be on the employee list at the Social Insurance Registration Office. The Office will confirm specific information with the employee for 2 purposes:
- to ensure the requesting party is an authorized employee
- to ensure the reason for the request is valid and meets the terms of the agreement
Report issues related to following this Code of Practice or other related policies. To report this, as a partner you should:
- contact the official listed on your agreement
- call toll-free at 1-866-274-6627, or
- if calling from outside Canada, call 1-506-548-7961 (long-distance charges apply)
5.3 Service Canada’s commitment to other authorized departments and agencies
Given Service Canada’s important role with its partners, we commit to:
- working with all SIR partners to enhance the integrity and accuracy of the SIR’s data
- ensuring the SIR’s long-term success by creating and maintaining:
- a clear governance and enforcement structure (described in agreements and addressing funding models)
- clear service needs
- clear information-sharing protocols
- maintaining open and transparent communication
- offering guidance, information and tools to help partners fulfil their SIN duties
Section 6 – Service Canada employees’ duties
In this section
- 6.1 Accuracy, privacy and security – Key duties of Service Canada employees and contractors
- 6.2 Information about the SIN and Service Canada Employees
- 6.3 Service Canada’s commitment to its employees
Service Canada employees and contractors like yourself play a key role with regard to Social Insurance Numbers (SINs). You help to protect the integrity, privacy, and security of the SIN. The Social Insurance Register (SIR) contains the client’s SIN and their personal information.
Service Canada keeps SINs and personal information in very secure program files that are highly confidential. As such, you should be very careful in the way you collect, retain, use and disclose this information. You are responsible for accurately and securely identifying and authenticating a person's identity. You play an important role in preventing fraud by ensuring that the right client gets the right benefit or service for the intended purpose. You must adhere to procedures that protect managing of personal information. Management of personal information includes collection, retention, use and disclosure.
6.1 Accuracy, privacy and security – Key duties of Service Canada employees and contractors
You are responsible for identifying and authenticating a person’s identity. You must do so correctly and securely. You play an important role in keeping clients' and employees' personal information safe. You help to prevent fraud and maintain the integrity of the information contained in the SIR.
You do so by ensuring that the right client gets the right benefit or service for the intended purpose. You are also responsible for reporting real and suspected incidents of fraud.
Note: Contractors, hired by Service Canada or a partner, who have access to information like SINs, have the same duties as Service Canada employees. Contractors must have the appropriate security clearance, “need to know” approval, and follow practices outlined in the Code.
1. All Service Canada employees and contractors must protect the privacy and security of clients’ personal information
You have a duty to protect personal information from unauthorized access, use or disclosure. You must be responsible with your access to electronic networks. You must sign an enforceable agreement to this effect.
You must respect the legislation and government policies and guidelines. The TBS and the Values and Ethics Code for the Public Sector detail these. There are policies that place further restrictions on the SIR's highly personal information. These policies give certain duties of disclosure to the Social Insurance Registration Office. You should also obey the Directive on Conflict of Interest of the Public Service.
Only authorized employees may access or request access to information in the SIR. You must have a specific "need to know” related to your assigned duties to do so. You then must follow established procedures. To access or disclose SIN information, you must be authorized and must need to do so as a function of your duties. You must follow legislation, policies and procedures that guide these duties.
You must confirm the identity of the requestor before disclosing SIN information. This step ensures the person receiving the information is the SIN holder or the legal representative. When you disclose SIN information to another Service Canada employee, you must confirm that this other employee should have this access.
When authorized partners send requests for SIN information, you must send these requests to the Social Insurance Registration Office. Only employees from this Office may reveal SIN information to these partners.
2. Service Canada employees must establish and authenticate a person’s identity by applying all Service Canada policies and procedures accurately and securely
Identifying clients accurately and securely is essential to lower the risk of fraud. It also helps to ensure that the right client gets the right benefit or service. Employees, like yourself, who register SIN applicants, must follow all related policies and procedures. Those who use the SIN to authenticate identity must compare the identity information provided on the Register. In doing so, you must follow Service Canada’s identity management policies.
You must fully review an individual’s record in the SIR to confirm that the SIN is valid. You must also ensure that there are no annotations or conditions that may affect its use. The required policy and procedures are on the Social Insurance Number overview website. This is for employees with direct access to the Register. Go to the website to inform yourself about the Proof-of-Identity Program. It also addresses SIN processing procedures and web-based training.
3. Service Canada employees must follow set rules to ensure that the information in the SIR is accurate and safe from unauthorized use
You must thoroughly compare and match the information from the SIR with the information provided by the client. The employee who found the issue must address any errors, inaccuracies or discrepancies in a person’s SIN record. If needed, you should apply the internal mechanisms and procedures. You should consult the relevant guidelines, training manuals and procedures for specific directives. You can also call the toll-free number 1-866-274-6627.
If the error is a data capture error, we will check if we can:
- correct it by phone, and
- if we can do so without contacting the client
If we cannot, the Social Insurance Registration Office will work with you, the partner, to inform the client about how to correct the data. The Office will also confirm what documentation the client will need to provide and the service options that are available to the client. This is the same approach for cases where the inaccuracy isn’t due to a data capture error.
A client’s SIN record may require special attention. In this case, you must act appropriately. This includes referring the issue to Integrity Services Investigators. Investigators or other actors may also direct an employee to the Social Insurance Registration Office.
6.2 Information about the SIN and Service Canada employees
The SIN record contains all of the personal information from when someone applied for their SIN or asked us to modify their information. Modifying information could include name changes, for example. The SIR contains this information. This information may include a person’s name, date of birth, place of birth and parents’ names. The SIN record also contains dates of death.
Where appropriate, the record may have specific conditions related to the SIN. The SIR also shows the status of inactive SINs and cross-referenced SINs. A SIN may have a pending file when a request is in progress or when a case warrants an annotation on the SIN record.
Service Canada employees, like yourself, who have access to the SIR have their own unique user code. With this code, the SIR records all of your actions (such as transactions and accesses) performed on the SIR. The SIN program receives a monthly report to track usage. It can request a detailed audit trail of any employee.
You cannot access or update your own SIN record. You’re also not allowed to access or update the SIN record of a family member, friend or colleague. You may only access, request, use or disclose SIN information if it is part of their assigned duties. You must not treat anyone preferentially. This is including family members, friends and colleagues. This means that you should not arrange to have their request dealt with sooner than others. Management will act correctively if employees break the rules of any act, code or policy.
Punitive measures for breaking the rules include verbal and written reprimand, suspension or demotion. Such measures may even include terminating employment. Employment and Social Development Canada legislation includes a Privacy Code. It lays out specific penalties. These penalties can be for unauthorized or inappropriate access, or for the use or disclosure of personal information. The maximum penalty is a fine of $10,000 and/or a jail term of 6 months.
Service Canada-authorized employees who don’t have direct access to the Register should contact the Social Insurance Registration Office to get SIN information. The Office can only release information if your group is an authorized Register user and if your name appears on the Office’s employee list. Specific information will be validated to ensure you’re authorized, and that your request is valid.
6.3 Service Canada’s commitment to its employees
At Service Canada, we commit to enabling our employees and contractors to fulfil their duties. We also commit to protecting the SIN from inappropriate use, fraud and theft. Employers and contractors have a duty to ensure that the Register is accurate, complete and secure. We commit to:
- ensuring that you are properly aware of the required procedures, guidance and tools to:
- authenticate identity
- validate proof-of-identity documents
- access and update the Register
- detect fraud
- creating online training tools that help you understand and fulfil your duties related to the Register
- providing you with a comprehensive support system:
- to inform you of key issues and priorities, and to provide answers to SIN-related questions
- local and regional SIN coordinators
- dedicated call centres
- intranet tools
- regular communication
- verifying that employees and contractors, like yourself, understand your duties
Annex 1: Authorized federal uses of the SIN
The Treasury Board Secretariat (TBS) of Canada’s maintains the Directive on Social Insurance Number. This Directive governs how federal government institutions collect, use and disclose the Social Insurance Number (SIN). The TBS also provides policy authority for some federal departments and agencies to collect use and disclose the SIN.
Federal government institutions can only collect or use the SIN for legally authorized purposes. A federal government institution must have either express legal authority, or implicit legal authority and Treasury Board policy approval.
Authorized uses of the SIN outlined in the Directive on Social Insurance Number (Appendix A) include:
- historical file retrieval
- lawful investigation and SIN collection and use
- other purposes related to administrating legislation (including taxation purposes)
- certain non-administrative purposes consistent with the administration of the Statistics Act, the Library and Archives of Canada Act and the Auditor General Act
For further information about authorized uses and a list of authorized programs and activities, see Appendix A of the Directive on Social Insurance Number.
Annex 2: SIN holder dos and don’ts: protecting your SIN
- Memorize your Social Insurance Number (SIN)
- Keep your SIN card or confirmation letter in a secure location (for example, a safety deposit box)
- When an organization requests your SIN, ask if the law requires them to collect the SIN and if not,
- ensure you're satisfied it is necessary to provide it, or
- offer other documents to fulfil their requirements (for example, your driver’s licence)
- Safeguard your mail from theft by locking your mailbox, especially when expecting a SIN confirmation letter
- Promptly remove mail received right after delivery
- Notify Canada Post to hold your mail if you plan to be away
- Go to the Get Cyber Safe - Canadian Centre for Cyber Security website to learn best practices for cyber security to keep your SIN safe
- Don’t use your SIN as a piece of identification as it puts your SIN and personal information at increased risk
- Don’t carry your SIN around with you; if you lose your SIN or if someone steals it, someone may use it fraudulently
- Don’t leave documents containing personal information, and, above all, the SIN, out in the open
- Don’t reveal your SIN to anyone, but, if you do, you:
- must be certain that the law entitles the person asking for your SIN to it
- assume the heightened potential risk of identity theft or fraud if you reveal your SIN to someone who isn`t legally entitled to it
- Don’t give your SIN over the phone unless you start the call and you know with whom you're dealing
- Don’t reply to emails that request personal information like a SIN as these emails are likely fraudulent
- Don’t send your personal information or SIN via cell-phones or laptops, for example, when you’re using an unsecured internet connection
- Don’t use a caller’s display information to confirm their identity, as criminals can alter display information and pretend to be someone else like:
- another person
- a representative of a company
- a representative of a government entity
Remember: Service Canada never initiates contact with someone by telephone or email requesting their SIN and/or credit card number. If you receive a telephone call or an email asking for this information it is a scam. If you’re contacted about owed payments, prepaid credit cards or gift cards, it is also a scam.
Annex 3: What to do if you suspect your SIN is compromised
Anyone can put the security of your Social Insurance Number (SIN) at risk. This includes yourself, or any organization that holds your SIN. It can happen by theft. This could be theft of your SIN card or confirmation letter. It could also be theft of documents containing your SIN, or of computer/electronic records containing your SIN. This could also be by disclosure. This can be either deliberate or by accident, to a person or an organization who isn’t trustworthy.
If your SIN is compromised, act quickly. This will help prevent loss and minimize the negative impact. Here are steps you should take immediately to lessen any potential damage.
SIN at risk: To do list
1. Figure out if any criminal activity (for example, theft or fraud) has taken place
If yes, contact your local police to file a complaint. Ask for the case reference number and the officer's name and telephone number. Make sure the report states your name and SIN. Also, contact the Canadian Anti-fraud Call Centre at 1-888-495-8501. This national call center provides advice on and help with identity theft.
2. Contact Equifax and TransUnion, Canada’s 2 national credit bureaus
Do so to request a free copy of your credit report so you can review this report for any suspicious activity. There is 1 free report issued per year. Consider a request to flag your credit file. This indicates that your personal information is at risk and is liable to fraud.
3. Inform your bank and creditors by phone and in writing to reduce your financial risk
Look for the contact information on the back of your bank card(s) and credit card(s).
4. When you receive mail, report any irregularities to Canada Post (1-866-607-6301)
This may include, for example, opened envelopes or missing financial statements or documents.
5. Visit a Service Canada Centre
Bring all the required documents proving SIN fraud or misuse. Check to find a Service Canada office close to you.
Bring an original proof-of-identity document (such as a birth certificate or an immigration or citizenship document). Also, bring a secondary document. Service Canada will use this to confirm your identity. An official will review the information, assist, and guide you. Service Canada agents will help you figure out what measures and precautions you should take with regard to your SIN.
6. At any time, you can get guidance from Service Canada
Call 1-866-274-6627 to do so. If you’re outside of Canada, you can call 1-506-548-7961.
Annex 4: What to do if your organization is handling privacy breaches involving SINs
This annex applies to any organization that is subject to PIPEDA or other provincial and territorial legislation. Follow any federal, provincial or territorial requirements or guidelines for handling privacy breaches and breach notification.
For cases where there are no such guidelines, the following guidelines may apply. For example, these guidelines may apply in the case of a breach of employee information of non-Federal workers. These guidelines explain required steps when notifying the proper authorities in cases of suspected theft or inappropriate disclosure of personal information, like the SIN.
Step 1: Assess the damage
Determine the type and extent of personal information compromised. Estimate what time it happened. If the case involves digital files, find out whether the data was encrypted. Some other questions to consider include the following:
- what information could be at risk?
- when did it occur?
- how did it happen?
- which files did the damage affect?
- in what format was the information stored?
- were any security measures in place?
- is other information at risk?
Step 2: Contact the police
If any criminal activity occurred, for example, theft or fraud, contact the police. You may also wish to contact the Canadian Anti-Fraud Call Centre (1-800-495-8501). This national anti-fraud call center provides advice and help about identity theft and helps people protect themselves from fraud. The Royal Canadian Mounted Police, the Ontario Provincial Police and the Competition Bureau Canada manage it.
Step 3: Contact Service Canada
Service Canada’s Social Insurance Registration Office can help you determine next steps. They can also help reduce the damage to victims. You may reach the office at 1-866-274-6627 or 1-506-548-7961 if calling from outside of Canada.
Step 4: Contact credit bureaus
Speak to fraud specialists at Canada’s 2 national credit bureaus. Discuss the type of warning help you need to respond to the incident.
Step 5: Contact all affected individuals
Organizations should contact the victims in writing as soon as possible. The letter should:
- explain the incident
- describe the measures taken
- provide advice on what the affected individual should do
- explain what type of information may be at risk
- provide contact information for further support, including:
- a representative from the organization
- Service Canada
- credit bureaus
Annex 5: Employers’ dos and don’ts: requesting, collecting, using and storing the SIN
- Request the Social Insurance Number (SIN) of new employees if the law requires it within 3 days of their start of employment
This does not prevent the individual from working before getting their SIN. They can continue working in insurable employment.
- Record the employee’s SIN in a secure area or on an encrypted computer system
- If in doubt about whether an employee’s SIN is valid, contact Service Canada’s Social Insurance Registration Office
This way you can verify the number. You can call them at 1-866-274-6627 within Canada. If you’re calling from outside Canada, the number is 1-506-548-7961. Long-distance charges apply.
- Be sure your new employee’s onboarding training includes key aspects about privacy of personal information and the SIN
- If a new employee’s SIN begins with a “9”, ensure that the work permit is valid.
Immigration, Refugees and Citizenship Canada (IRCC) issue the work permit. Follow all terms and conditions of the work permit.
- Go to the Get Cyber Safe - Canadian Centre for Cyber Security website to learn best practices for cyber security.
These tips will help you keep the personal information and SIN of your employees safe.
- Don’t ask for the SIN on a job application or during an interview
- Don’t use the SIN as an employee identification number; use a unique identifier for your organization
- Don’t hire someone who doesn't have a verified valid SIN except in cases where the employee provides proof that they've applied for a SIN
- Don’t give an employee’s SIN to anyone unless they’re entitled by law to that information (for example, for income tax or government benefit purposes)
- Don’t hire anyone without ensuring they’re authorized to work in your industry in Canada
- Don’t allow SIN fraud to go unreported; report suspected fraudulent use of a SIN by contacting Service Canada
- Don’t leave documents containing employees’ personal information or SINs in the open
Annex 6: Private sector dos and don’ts: requesting, collecting, using and storing the SIN
- Properly identify the client’s identity by requesting valid proof-of-identity documents (the SIN is not an identity document)
- Get your client’s consent before collecting, using or disclosing any personal information or their Social Insurance Number (SIN)
- Give clients an alternative to providing their SIN when a credit check is necessary
- Inform clients what type of personal information you're collecting, why you are collecting it and for what purposes your business will use it
- Keep sensitive information in a secure area or an encrypted computer system limited to a “need-to-know” basis only
- Shred all paper records that you no longer need and erase/remove any electronic records containing personal information like the SIN before disposal
- Choose someone in your organization or business to act as a Chief Privacy Officer (CPO)
The CPO handles all privacy issues. Establish a privacy management framework that includes auditable performance privacy and security practices. Ensure the CPO is accountable to senior management. The CPO must have authority to intervene on privacy issues in your organization. Take data security and privacy protection seriously.
- Train all employees on privacy policies
Keep them informed. This is so they can respond to ongoing questions and concerns from clients. Make those policies available to all employees.
- Don’t use clients’ personal information, including the SIN, for any purpose which you are not permitted
- Don’t use the SIN as a client identification number or to identify someone in normal commercial transactions
- Don’t collect the SIN and other personal information, unless required by law
- Don’t ask for a client’s personal information, and, above all, the SIN, via email
- Don’t put any client’s personal information on the Internet
- Don’t sell or provide clients’ personal information to third-party organizations or companies unless you have your clients’ consent
- Don’t disclose a person’s SIN to anyone unless you know they’re entitled by law to that information
- Don’t deny a client a product or service for refusing to provide their SIN unless the law requires it (for example, registered income product)
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