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Government of Canada Response
To the Second Report of the Standing Committee on Human Resources Development and the Status of Persons with Disabilities: Taking the Necessary Measures to Enhance the Integrity of the Social Insurance Number: A Review of the Action Plan.
Introduction
The Government of Canada is pleased to respond to the Second Report of the Standing Committee on Human Resources Development and the Status of Persons with Disabilities, Taking the Necessary Measures to Enhance the Integrity of the Social Insurance Number: A Review of the Action Plan, which was tabled in the House of Commons on February 28, 2003.
The Government welcomes the Report, which focuses on the Human Resources Development Canada (HRDC) Social Insurance Number (SIN) Action Plan of February 11, 2003. This Plan builds on the previous and ongoing work of the department to improve SIN-related activities. It addresses issues that the 2002 Status Report of the Auditor General, Chapter 1, The Integrity of the Social Insurance Number identified.
Given the importance of the SIN to government services and to Canadians, the Government recognizes the need to be rigorous in ensuring the integrity of the system used to manage and control it. With the heightened awareness of security following the events of September 11, 2001 and the rise in automation and data linkage in our increasingly technological society, the SIN and potential for its misuse have come under increased scrutiny. HRDC is working towards balancing the citizen-focused service aspect of the SIN with increased measures to protect personal privacy and security. For example, where certified copies of personal identification could once be submitted by mail (in the interest of service) we now require original documents (to improve security).
HRDC has implemented a substantial range of improvements to SIN processes to address concerns including fraud and abuse of government programs.
The Government is pleased to note the support of the Auditor General and the Standing Committee for the efforts to date. It takes seriously the concerns that these efforts need to be extended, with the Action Plan being a focal point for planning and reporting on that work. It acknowledges that priorities for action should be to allocate needed resources for these efforts, continue improvements to the proof of identity requirements and expand communications with Canadians.
As the detailed responses to the recommendations of the Standing Committee indicate, the Government will reinforce and build on its agenda – one that has resulted in a steadily more secure SIN system. The Government values the Committee’s encouragement to continue its efforts to improve the integrity of the SIN and the Social Insurance Register (SIR), which contains the required information on SIN holders.
Moving Forward
HRDC has moved ahead by implementing measures that address a number of key issues. For example, the Committee highlighted the need to ensure accurate identification of SIN applicants and to ensure the quality of data in the SIR. As the
Committee stated, establishing identity is important to protect privacy, security and the integrity of publicly funded services.
HRDC has implemented changes that now make only two foundation documents acceptable to support a SIN application: either birth certificates or immigration and citizenship documents. This is a significant decrease in the number of acceptable original documents. These changes are in line with a proof of identity approach that is supported by the Federal/Provincial/Territorial Council on Identity in Canada. In response to a related concern, HRDC began to introduce expiry dates on the 900 series of temporary SINs on March 30, 2003. These cards bear an expiry date while individuals already in possession of a 900 series SIN must show proof of need and renew their cards by April 2004.
The Government recognizes the need for accurate authentication of SIN applicants and those using SINs that have already been issued. The information in the SIR database is expected to become a primary building block in authenticating the identity of users of many SIN-authorized HRDC services that will be delivered electronically, just as it is now for services delivered in person, by mail or over the telephone. To achieve this goal, verification of client information in the SIR database as part of a transaction with a client will need to be fast, seamless and respectful of privacy considerations.
Consistent with this direction, the Action Plan shows the Government’s commitment to additional improvements to the management of the SIN and the SIR. Just as HRDC works with the Canada Customs and Revenue Agency (CCRA) to identify potential concerns about SINs that already exist, HRDC is encouraging the development of electronic interfaces with provincial and territorial vital statistics agencies and with Citizenship and Immigration Canada (CIC) to verify information when a person applies for a SIN. Many initiatives within the Action Plan will require the continued support and advice of the Office of the Privacy Commissioner.
These measures would build on the experience of an existing agreement with New Brunswick, which enables 15,000 clients a year who were born in that province to apply for their SIN by phone. Similar agreements with provincial and territorial vital statistics agencies are being pursued.
The security and reliability of the SIR are essential to the integrity of the SIN. Once the status of the SIR is assessed, measures to improve the level of reliability either as a whole or in specific areas will be put in place.
While HRDC is making every effort to improve the management of the SIN, the existing system must continue to perform effectively and efficiently throughout the transition from traditional manual systems to highly automated ones. A number of issues will continue to present challenges no matter what system is in place, most notably accurately identifying the individual presenting identification documents when seeking a SIN. The Department is conscious of the need for and committed to constant monitoring and improvement.
The Government is also committed to improving the understanding of Canadians about how to apply for, use and safeguard their SINs. The Government appreciates the need to raise awareness among Canadians that the SIN is meant to be a file identifier for government benefit and taxation purposes, and not an identity document. It accepts the need to ensure the integrity and reliability of the SIR database so that Canadians are confident about the information it contains and the use made of it.
RESPONSE TO THE RECOMMENDATIONS
Responses to the four sets of recommendations in the Report are set out below in the order of the Report. Responses have been numbered for ease of reference.
RECOMMENDATION I - FUNDING
The Committee recommends that the government ensure that adequate funding be made available through new or existing resources so as to ensure the successful implementation of all the elements of the Social Insurance Number Action Plan and any other measure that may be required to restore the integrity of the SIN and the SIR.
The Government is committed to the full and successful implementation of the Action Plan.
The Government notes that, through Human Resources Development Canada in particular, it has already allocated resources to a variety of activities such as developing a formal training course for HRDC staff, purchasing tools for staff serving the public, updating databases, Intranet/Internet sites, and on-line access to information systems and disseminating new and revised pamphlets and other communications materials.
The Government allocated an additional $10.2 million over two years (April 2001-March 2003) to HRDC with an additional $10.8 million in 2002-03. The Department will continue to allocate resources for this purpose in 2003-04 and seek additional funding, if necessary.
This funding has assisted HRDC to deliver on many commitments incorporated in the Action Plan. The Department has initiated discussions with the National Vital Statistics Council and the governments of British Columbia, Ontario and Quebec. Projects for Date of Birth and Place of Birth Correction have been successfully completed. The Project for Date of Death Correction is under way. The use of expiry dates for the 900 series SINs was introduced on March 30, 2003, on schedule. All development for the creation of the SIN Dormant Flag and file updates for key partners were also completed by March 30, 2003. Work with CCRA continues on the use of CCRA data to improve the integrity of the SIR.
Funding was also allocated to the purchase of new hardware for authentication services, systems design and development, testing, quality assurance and other activities. This contributed to improving the integrity of the SIR and putting HRDC in a better position to work with its partners.
HRDC is assessing its resource requirements for SIN improvements in concert with its broader initiative of Modernizing Service for Canadians.
RECOMMENDATION II - RESPECTING THE LEGISLATION UNDERLYING THE SIN
Recommendation II included three specific recommendations. Recommendations a) and b) are considered jointly and recommendation c) follows below.
- The Committee recommends that Human Resources Development Canada immediately require all new applicants for a SIN to provide, in addition to one of the currently accepted primary documents, one other document that contains a photograph of the applicant (e.g., passport, driver’s license, etc.) or, if photo identification is not possible, at least two other identification documents.
- The Committee further recommends that by 1 January 2004, Human Resources Development Canada determine which type of photo identification documents will be required to apply for a Social Insurance Number, including photographs accompanied by a guarantor’s declaration like that required when applying for a Canadian Passport.
The Government agrees in principle with the recommendation to provide satisfactory proof of identity as well as the need to link the identity document with the individual. It notes that the fundamental concern in accurately identifying an individual is first to determine the authenticity of the identity document being used as proof of identity, and second, to link the document with the applicant.
Changes to improve the accurate identification of individuals have been made. Applicants for a SIN are now required to provide one of two foundation documents: a birth certificate or immigration and citizenship documents. To ensure the authenticity of these documents, HRDC purchased specialized equipment and trained staff in its use for the detection of false documents; provided staff who process SIN applications with the Identity Document Guide; introduced the SIN Application Review Process (SARP) to assist in identifying fraudulent applications; and, as a first step with the provinces/territories, developed a direct link to the New Brunswick Vital Statistics agency to verify the identity of individuals born in that province.
Some 90 percent of SIN applicants visit an HRDC office to present their original identity documents. This includes parents or guardians requesting a SIN for a child who must also produce their own identification. In addition to the foundation documents, HRDC officials may request other information to determine identity and status. In the case of inconsistencies or discrepancies, follow-up measures are implemented.
As part of the comprehensive risk-management approach to the SIN, HRDC will expand the SARP which uses an outline of selection criteria for applications requiring further review/intervention before a SIN is issued. This is an effective method of identifying “high risk” SIN applications and preventing abuse.
The Government understands the interest of the Committee in achieving the strongest possible proof of identity for the SIN application process. This need extends well beyond SIN activities, as many federal programs and services face proof of identity considerations.
However, there are limitations to seeking photo identification. Approximately 90 percent of SIN applicants are 16 years of age or younger while approximately 23 percent are 2 years of age or younger. This trend among Canadians who are unlikely to have formal photo identification is growing because of programs that require a SIN for children such as the Canada Education Savings Grant. In addition, many immigrants and refugees may not have appropriate photo identification beyond their primary immigration documents. Members of severely disadvantaged groups such as the homeless may not have or be able to obtain adequate photo or other identification.
Two complementary initiatives are under way to consider these questions. The first is the Policy Committee on Document Integrity, which is led by CIC. This Committee works with the Federal/Provincial/Territorial Council on Identity which is chaired by the Department of Foreign Affairs and International Trade. The results of their work could assist HRDC in determining which measures it will adopt.
The second initiative is an Interdepartmental Working Group (IWG) that HRDC has established to undertake a comprehensive review of the proof of identity requirements. The Department will consider its recommendations, which are expected at the end of September 2003. The Working Group has been made aware of the Committee’s recommendations and its work will analyze the risks, benefits and costs of any type of improved proof of identity procedures.
The Government will review carefully the conclusions and recommendations that these groups put forward.
- The Committee recommends that once the government has made a decision regarding photo identification documents, the government amend the Employment Insurance Regulations to list all acceptable identification documents and to require individuals to provide at least two original identity documents, including one photo identity document, when applying for a Social Insurance Number.
HRDC agrees to review the Employment Insurance (EI) Regulations once the list of documents is determined, and to take into consideration the requirements of the Passport Office Order and similar requirements in use in other departments and agencies.
Existing EI Regulations provide the authority to request documents and other information to determine the identity and status of a person. These documents could include photographs.
RECOMMENDATION III - APPROPRIATE USE OF THE SIN AND PERSONAL INFORMATION ON APPLICANTS
Recommendation III included three specific recommendations, which are discussed below as a), b) and c).
- The Committee recommends that Human Resources Development Canada reassess its plans for the 2003-2004 communication strategy to inform specific groups on the proper use of the SIN with a view to delivering this strategy to a larger public by using, for example, the national media as recommended in Chapter 11 of the 2002 Report of the Auditor General of Canada.
HRDC agrees with this recommendation. It will continue to develop and implement its 2003-2004 communications strategy, with a view to reaching a broader public and better achieving its goal that Canadians understand how to apply for, use and safeguard their SINs. To accomplish this, it intends to target key stakeholders and the Canadian public. It will work with other Government departments involved with the SIN (e.g., CIC and CCRA).
Reviewing communications effectiveness will be particularly important when the final phase of the Personal Information Protection and Electronic Documents Act (PIPEDA) comes into force in January 2004. The Act has implications for the SIN that need to be communicated to Canadians. HRDC is coordinating its efforts with Industry Canada, the lead department for implementing this Act.
HRDC is taking a pragmatic approach to communications about the SIN and has already completed some public opinion research, the first phase in the Department’s overarching communications plan of action. By analyzing opinions received, HRDC has learned that the communications products it uses to inform Canadians about their SIN are effective.
HRDC has already conducted two types of public opinion research to guide its efforts to enhance communications about the SIN. Focus groups held in January 2003 in Toronto, Montréal, Halifax and Vancouver show that focus group participants have a fair knowledge and awareness of the SIN and their attitudes towards it are positive. Participants found SIN communications products to be clear and useful and their reaction was largely positive.
Quantitative research in the form of a survey about Canadians’ perception of the SIN was conducted in February 2003 and showed some gaps in awareness. For example, 51 percent of Canadians believe their SIN is used as a form of personal identification and the same number believe that it is required (as opposed to optional) for a credit check. The survey found that 62 percent of Canadians keep the card in their wallet or on their person, in spite of efforts to communicate that the card should be kept in a safe place.
As outlined in the SIN Action Plan, the Department’s comprehensive SIN communications strategy for 2003-2004 will draw on findings from the public survey and the focus groups, as well as communications experience to date. HRDC will adapt SIN communications products as these are reprinted. Upcoming publications will set out the penalties people face for committing fraud under the EI Act and the legal consequences of using the SIN fraudulently.
The communications strategy for 2003-04 will build on recent work to support the regulatory change introducing expiry dates for 900 series SINs. At the time of the change, HRDC issued a press release and backgrounder to the national media, and distributed MP kits and posted information on the MP Intranet site. A new publication, Expiry Dates for 900 Series SINs, is aimed at those applying for a 900 series Number.
Beginning in 2003-04, HRDC plans to target two specific audiences: people holding 900 series SIN cards and employers who may have employees with 900 series SINs. For 900 series SIN holders, this approach may include multi-language public service announcements for ethnic media. For employers, HRDC has updated its publication Employers and Social Insurance Numbers (SIN): What you need to know and will address the issue at the Canadian Payroll Association conference in June 2003 among other methods.
To conclude, a variety of strategic communications approaches will guide HRDC's efforts to communicate broadly about the SIN in 2003-2004. In all cases, HRDC will look for creative, pragmatic and cost-effective ways to reach the most affected Canadians.
- The Committee recommends that the Treasury Board act quickly to revise its policy and guidelines if warranted by the Secretariat’s findings regarding compliance of federal institutions with policies on the use of the SIN.
The Government agrees with the Committee's recommendation and will act quickly to complete any revisions to the policy that might be necessary. Treasury Board Secretariat (TBS) officials will be presenting the key findings of the review of the SIN and data matching components of the Treasury Board Policy on Privacy and Data Protection to the President of the Treasury Board in the near future. Any amendments or recommendations for changes to the Policy and its related guidelines would subsequently be presented to the Treasury Board for consideration and approval.
The TB Policy limits the administrative uses of the SIN by federal institutions to specific purposes including pensions, income tax, health and social programs. The reliability of the SIN as a file identifier and the integrity of the SIR are responsibilities of HRDC and, therefore, were not addressed during the course of the TBS review.
- The Committee recommends that one year after the complete implementation of the Personal Information Protection and Electronic Documents Act, the government conduct a review to determine if specific legislation is required to curb the improper use of the SIN.
Industry Canada will begin its review of the Personal Information Protection and Electronic Documents Act (PIPEDA) in 2005, in accordance with the requirements of the Act and will take into consideration all matters brought to its attention by other departments, including issues related to the SIN.
RECOMMENDATION IV - DEADLINES AND PROGRESS REPORTING
Recommendation IV included two specific recommendations, which are discussed below as a) and b).
- The Committee recommends that Human Resources Development Canada include in its Action Plan deadlines for achieving all of the actions associated with the 14 initiatives listed in the Plan.
HRDC agrees with the recommendation.
The Department has set target completion dates for the 14 initiatives and is monitoring progress. Some of these initiatives are interdependent and progress in one area – including in other departments and by partners - will have effects on the scope and pace of progress in other areas.
- The Committee recommends that Human Resources Development Canada provide semi-annual progress reports to the Auditor General of Canada and the Standing Committee on Human Resources Development and the Status of Persons with Disabilities outlining the status of all of the actions associated with the 14 initiatives in the Plan. In instances where deadlines are missed, an explanation and a description of corrective action to be taken should be provided.
HRDC agrees with the recommendation and will keep the Auditor General and Standing Committee informed of its progress. These progress reports will coincide with the timing of its Departmental Performance Report and its Report on Plans and Priorities.
CONCLUSION
The Government is pleased that the Committee recognizes the progress to date on significant steps to improve the integrity of the SIN process and the integrity of the Register. It will continue to enhance the SIN through active implementation of the Action Plan and any other necessary measures, reflecting the guidance of the Committee.
TAKING THE NECESSARY MEASURES TO ENHANCE THE INTEGRITY OF THE SOCIAL INSURANCE NUMBER: A REVIEW OF THE ACTION PLAN
Report Recommendations
RECOMMENDATION 1
The Committee recommends that the government ensure that adequate funding be made available through new or existing sources so as to ensure the successful implementation of all the elements of the Social Insurance Number Action Plan and any other measure that may be required to restore the integrity of the SIN and the SIR.
RECOMMENDATION 2
The Committee recommends that:
- Human Resources Development Canada immediately require all new applicants for a SIN to provide, in addition to one of the currently accepted primary documents, one other document that contains a photograph of the applicant (e.g., passport, driver’s licence, etc.) or, if photo identification is not possible, at least two other identification documents;
- By 1 January 2004, Human Resources Development Canada determine which type of photo identification documents will be required to apply for a Social Insurance Number, including photographs accompanied by a guarantor’s declaration like that required when applying for a Canadian Passport;
- Once the government has made a decision regarding photo identification documents, the government amend the Employment Insurance Regulations to list all acceptable identification documents and to require individuals to provide at least two original identity documents, including one photo identity document, when applying for a Social Insurance Number.
RECOMMENDATION 3
The Committee recommends that:
- Human Resources Development Canada reassess its plans for the 2003-2004 communication strategy to inform specific groups on the proper use of the SIN with a view to delivering this strategy to a larger public by using, for example, the national media as recommended in Chapter 11 of the 2002 Report of the Auditor General of Canada;
- The Treasury Board act quickly to revise its policy and guidelines if warranted by the Secretariat’s findings regarding compliance of federal institutions with policies on the use of the SIN;
- One year after the complete implementation of the PIPEDA, the government conduct a review to determine if specific legislation is required to curb the improper use of the SIN.
RECOMMENDATION 4
The Committee recommends that:
- Human Resources Development Canada include in its Action Plan deadlines for achieving all of the actions associated with the 14 initiatives listed in the Plan;
- Human Resources Development Canada provide semi-annual progress reports to the Auditor General of Canada and the Standing Committee on Human Resources Development and the Status of Persons with Disabilities outlining the status of all of the actions associated with the 14 initiatives in the Plan. In instances where deadlines are missed, an explanation and a description of corrective action to be taken should be provided.