The Social Insurance Number Code of Practice Section 6 - Service Canada employees' responsibilities
Service Canada employees and contractors play a critical role in protecting the integrity, privacy and security of the Social Insurance Number (SIN). Because the SIN and the client's identity information are contained in the Social Insurance Register (the Register) and on program files that are highly confidential, employees should be extremely careful in the way they collect, retain, use and disclose this important personal information.
Service Canada employees are responsible for accurately and securely identifying and authenticating a person's identity. Employees play an important role in preventing fraud by ensuring that the right client gets the right benefit or service for the intended purpose. They are also responsible for the integrity of the information contained in the Register.
6.1 Accuracy, privacy and security – Key responsibilities of Service Canada employees and contractors Footnote 1
1. All Service Canada employees and contractors must rigorously protect the privacy and security of clients' personal information.
- In carrying out their duties, employees and contractors must protect the SIN and other identity information from unauthorized access, use or disclosure according to legislation and policy.
- To access or request access to information in the Register, an employee must be authorized, must have a specific “need to know” related to their assigned duties, and must follow established procedures.
- To disclose SIN information, the employee must be authorized and required to do so as a function of his or her duties. The employee must follow legislation, policies and procedures.
- When disclosing SIN information to an individual or his/her legal representative, the employee must ensure the person receiving the information is, in fact, the SIN holder or his/her legal representative.
- When disclosing SIN information to another Service Canada employee, the employee must ensure that the person is authorized to see the information as a function of their duties.
- Employees must refer requests for SIN information from an authorized partner to the Social Insurance Registration Office in Bathurst, New Brunswick. Only Bathurst employees are allowed to reveal SIN information to these partners.
For more information see Annex 8, Service Canada Employees’ Dos and Don'ts: Protecting the Privacy and Security of the SIN.
2. Service Canada employees must carefully apply all Service Canada policies and procedures to establish and authenticate an individual's identity, accurately and securely.
- Accurate and secure identification of individuals is essential to prevent fraud and ensure that the right client gets the right benefit or service.
- Employees who register SIN applicants must follow the Proof-of-Identity (PID) Program, the SIN Application Review Process (SARP), and all other related policies and procedures.
- Employees who use the SIN to authenticate identity must compare the identity information provided on the Register and follow Service Canada's Identity Management Policy (under development), including the PID program.
- Employees must fully review an individual's record in the Register to confirm the SIN is valid and there are no annotations or conditions that may affect its use.
3. Service Canada employees must ensure that the information in the Register is accurate and safe from unauthorized use. They must also take all appropriate action specified by instructions in the Register.
- Employees must fully compare the information from the Register with information provided by the client to ensure they match.
- Employees who spot a discrepancy, error or inaccuracy in an individual's SIN record must ensure the information is corrected.
- When a client's SIN record has a condition that requires special attention, employees must take the appropriate action, such as referral to an Integrity Services Investigators, or to the Social Insurance Registration Office.
Note: When a contractor hired by Service Canada or its partners has access to the SIN or other personal information, they have the same responsibilities as Service Canada, its partners and their employees. Contractors must meet the requirement for “need to know”, have the appropriate security clearance and follow practices outlined in the Code.
6.2 Questions and answers about the SIN and Service Canada employees
1. What information does an individual's SIN record contain?
The SIN record contains basic requested identity information when a person applies for a SIN or asks to update his or her SIN record. This information is contained in an electronic database called the Social Insurance Register (the Register). It consists of the SIN assigned to the individual, the name (given names and surname), date of birth, and other information provided at the time of application, including gender and the full names at birth of the parents and place of birth. The SIN record may have names contained in the last primary document provided (if applicable) and any other surnames used by the SIN holder. Where appropriate, the record may have specific conditions related to the SIN. The status of inactive SINs and cross-referenced SINs are also shown. A SIN may have a pending file when a request is in progress or when a situation warrants an annotation on the SIN record.
2. What legislation governs employee access and use of SIN information?
All federal employees should comply with the Values and Ethics Code for the Public Service and the Privacy Act , which describes the collection, retention, use and disclosure of personal information. Due to the highly personal nature of information in the Register, there are policies that place further restrictions on its information and give certain responsibilities of disclosure to the Social Insurance Registration Office in Bathurst, New Brunswick. Former employees should also obey the Conflict of Interest and Post-Employment Code of the Public Service.
3. How is employee access monitored?
All accesses and transactions for each employee's Register user code are recorded. Managers receive a monthly report to monitor usage and can request a detailed audit trail of any employee. Disciplinary measures for breaking rules range from verbal and written reprimand, suspension, demotion and can even result in termination of employment. Employment and Social Development Canada legislation includes a Privacy Code with specific penalties for unauthorized or inappropriate access, use or disclosure of personal information. The maximum penalty is a fine of $10,000 and/or a jail term of six months.
4. Are employees working with the SIN allowed access to the Register to verify or update information related to themselves, a family member or a friend?
Employees must never access or update their own SIN record or the SIN record of a family member, friend or colleague. They may only access, request, use or disclose SIN information if it is part of their assigned duties. When there is a legitimate request, for example, to correct their own date of birth on their SIN record, all procedures and policies must be followed. They must not give preferential treatment to any individual, including family members, friends and colleagues. This means they should not arrange to have their request dealt with sooner than others. Access to the Register is monitored. Management will take disciplinary action if employees break the rules of any act, code or policy. For more information, see Annex 8, Dos and Don'ts for Employees: Protecting the Privacy and Security of the SIN.
5. What should employees do when information in the Register is inaccurate?
When employees find an error on a client's SIN record, they should inform Service Canada by calling 1-866-274-6627. Data-capture errors can be corrected immediately. If it is not a data-capture error, the Office will tell the client how to correct the data and what documents are required.
6. What should employees do if their client's SIN record has a condition?
Service Canada employees must follow the specific directives and take appropriate action when a client's SIN record contains an annotation or a condition. Employees should consult the relevant guidelines, training manuals and procedures for specific directives, or call toll-free at 1-866-274-6627.
7. What is the role of Integrity Services Investigators?
Integrity Services Investigators (ISI) prevent, detect and deter improper use of the SIN and thereby protect the integrity of public funds. They also assist the Social Insurance Registration Office to administer and control the SIN program, including the Register. Each Service Canada Centre has ISI support, either on-site or available from a parent office.
8. What information and tools are available to assist Service Canada employees?
Employees with direct access to the Register will find the necessary policy and procedures on the Register intranet website. The website has information on the Proof-of-Identity Program, SIN processing procedures, web-based training, and useful references and links.
9. If employees do not have access to the Register, how can they obtain information?
Employees who are authorized to obtain SIN information, but who do not have direct access to the Register, can contact the Social Insurance Registration Office for the necessary information. The Office can only release information to employees if their group is an authorized Register user and their name appears on the employee list maintained by the Office. Specific information will be validated to ensure they are authorized and their request is valid.
6.3 Service Canada's commitment to its employees
Service Canada is committed to enabling its employees and contractors to fulfil their responsibilities to protect the SIN from inappropriate use, fraud and theft, and to ensure that the Register is accurate, complete and secure. Service Canada is committed to:
- ensuring that employees have the required information, procedures, guidance and tools to authenticate identity, validate proof-of-identity documents, access and update the Register, and detect fraud.
- creating online training tools to help employees understand and fulfill their responsibilities related to the Register.
- providing employees with a comprehensive support system (including local and regional SIN coordinators, a dedicated call centre, intranet tools and regular communication) to inform them of key issues and priorities, and provide answers to SIN-related questions.
- verifying that employees and contractors understand their obligations with respect to the privacy, security and integrity of the SIN and other personal information.
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