Social Security Numbers
Governments Could Do More to Reduce Display in Public Records and on Identity Cards Gao ID: GAO-05-59 November 9, 2004While the use of Social Security numbers (SSN) can be very beneficial to the public sector, SSNs are also a key piece of information used for committing identity crimes. The widespread use of SSNs by both the public and private sectors and their display in public records have raised concern over how SSNs might be misused and how they should be protected. In light of this concern, GAO was asked to examine (1) the extent to which SSNs are visible in records made available to the public, (2) the reasons for which governments collect SSNs in records that display them to the public, and (3) the formats in which these records are stored and ways that the public gains access to them. As well as looking at public records, GAO also examined the practices of several federal agencies regarding the display of entire nine-digit SSNs on health insurance and other identification cards issued under their authority.
Social Security numbers appear in any number of records exposed to public view almost everywhere in the nation, primarily at the state and local levels of government. State agencies in 41 states and the District of Columbia reported visible SSNs in at least one type of record and a few states have them in as many as 10 or more different records. SSNs are most often to be found in state and local court records and in local property ownership records, but they are also scattered throughout a variety of other government records. In general, federal agency display of SSNs in public records is prohibited under the Privacy Act of 1974. While the act does not apply to the federal courts, they have taken action in recent years to prevent public access. With regard to the SSNs maintained in public records, various state and local officials commonly reported needing them for identity verification. A few, however, said they had no use for the SSN, but that documents submitted to their offices often contained them. States also commonly reported using the SSN to facilitate the matching of information from one record to another. The federal courts largely collect SSNs when required by law to do so; however, due to privacy concerns, SSNs are not in documents that are available electronically to the public. Public records with SSNs are stored in a multiplicity of formats, but public access to them is most often limited to the inspection of individual paper copies on site or via mail by request. Few state agencies make records with SSNs available on the Internet; however, 15 to 28 percent of the nation's 3,141 counties do place them on the Internet and this could affect millions of people. Overall, GAO found that the risk of exposure for SSNs in public records at the state and local levels is highly variable and difficult for any one individual to anticipate or prevent. Another form of SSN exposure results from a government practice that does not involve public records per se. GAO found that SSNs are displayed on cards issued to millions of individuals under the authority of federal agencies for identity purposes and health benefits. This involves approximately 42 million Medicare cards, 8 million Department of Defense identification cards, as well as some insurance cards, and 7 million Veterans Affairs identification cards, which display the full nine-digit SSN. While some of these agencies are taking steps to remove the SSNs, there is no governmentwide federal policy that prohibits their display. Although we did not examine this phenomenon across all federal programs, it is clear that the lack of a broad, uniform policy allows for unnecessary exposure of personal Social Security numbers.
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Report to the Chairman, Subcommittee on Social Security, Committee on
Ways and Means, House of Representatives:
United States Government Accountability Office:
GAO:
November 2004:
Social Security Numbers:
Governments Could Do More to Reduce Display in Public Records and on
Identity Cards:
GAO-05-59:
GAO Highlights:
Highlights of GAO-05-59, a report to the Chairman, Subcommittee on
Social Security, Committee on Ways and Means, House of Representatives:
Why GAO Did This Study:
While the use of Social Security numbers (SSN) can be very beneficial
to the public sector, SSNs are also a key piece of information used for
committing identity crimes. The widespread use of SSNs by both the
public and private sectors and their display in public records have
raised concern over how SSNs might be misused and how they should be
protected. In light of this concern, GAO was asked to examine (1) the
extent to which SSNs are visible in records made available to the
public, (2) the reasons for which governments collect SSNs in records
that display them to the public, and (3) the formats in which these
records are stored and ways that the public gains access to them. As
well as looking at public records, GAO also examined the practices of
several federal agencies regarding the display of entire nine-digit
SSNs on health insurance and other identification cards issued under
their authority.
What GAO Found:
Social Security numbers appear in any number of records exposed to
public view almost everywhere in the nation, primarily at the state and
local levels of government. State agencies in 41 states and the
District of Columbia reported visible SSNs in at least one type of
record and a few states have them in as many as 10 or more different
records. SSNs are most often to be found in state and local court
records and in local property ownership records, but they are also
scattered throughout a variety of other government records. In general,
federal agency display of SSNs in public records is prohibited under
the Privacy Act of 1974. While the act does not apply to the federal
courts, they have taken action in recent years to prevent public
access.
With regard to the SSNs maintained in public records, various state and
local officials commonly reported needing them for identity
verification. A few, however, said they had no use for the SSN, but
that documents submitted to their offices often contained them. States
also commonly reported using the SSN to facilitate the matching of
information from one record to another. The federal courts largely
collect SSNs when required by law to do so; however, due to privacy
concerns, SSNs are not in documents that are available electronically
to the public.
Public records with SSNs are stored in a multiplicity of formats, but
public access to them is most often limited to the inspection of
individual paper copies on site or via mail by request. Few state
agencies make records with SSNs available on the Internet; however, 15
to 28 percent of the nation‘s 3,141 counties do place them on the
Internet and this could affect millions of people. Overall, GAO found
that the risk of exposure for SSNs in public records at the state and
local levels is highly variable and difficult for any one individual to
anticipate or prevent.
Another form of SSN exposure results from a government practice that
does not involve public records per se. GAO found that SSNs are
displayed on cards issued to millions of individuals under the
authority of federal agencies for identity purposes and health
benefits. This involves approximately 42 million Medicare cards, 8
million Department of Defense identification cards, as well as some
insurance cards, and 7 million Veterans Affairs identification cards,
which display the full nine-digit SSN. While some of these agencies are
taking steps to remove the SSNs, there is no governmentwide federal
policy that prohibits their display. Although we did not examine this
phenomenon across all federal programs, it is clear that the lack of a
broad, uniform policy allows for unnecessary exposure of personal
Social Security numbers.
What GAO Recommends:
GAO recommends that the Office of Management and Budget identify those
federal activities that require or engage in the display of SSNs on
health insurance, identification, or any other cards issued to federal
government personnel or program beneficiaries, and devise a
governmentwide policy to ensure a consistent approach to this type of
display. All agencies that reviewed a draft of this report generally
agreed with our findings and recommendation.
www.gao.gov/cgi-bin/getrpt?GAO-05-59.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Barbara Bovbjerg at
(202) 512-7215 or bovbjergb@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
SSNs Are Widely Exposed in a Variety of Public Records Held by States,
Local Jurisdictions, and Courts, but Less Exposed in Federal Records:
Identity Verification Is the Most Common Use of SSNs in Public Records:
Public Documents with SSNs Are Stored in a Multiplicity of Formats, but
Hard Copy Is Still the Most Widely Available Form of Public Access:
Millions of Federal Health Insurance and Identity Cards Display the
SSN:
Conclusions:
Recommendation:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: State and Local Government Survey Questions:
Appendix III: State Survey Response Rates by Function and State:
Appendix IV: Extent of SSN Availability in State Public Records:
Appendix V: Types of Public Records Held by Local Government Offices:
Appendix VI: Comments from the Department of Defense:
Appendix VII: Comments from the Office of Personnel Management:
Appendix VIII: Comments from the Social Security Administration:
Appendix IX: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Tables:
Table 1: Availability of Public Records Containing SSNs by Number of
States:
Table 2: Reasons Reported by State Agencies for Collecting or Using
SSNs That Are Displayed in Public Records:
Table 3: A Sample of Responses from County Officials Who Selected
"Other" in Response to "Why does your office collect or use SSNs" for
Specific Types of Records:
Table 4: State Office Use of Multiple Storage Methods for Specific
Types of Records Containing SSNs:
Table 5: Recent State Laws Restricting Public Disclosure of SSNs Cited
by Survey Respondents:
Table 6: Out of Sample Respondents and Reasons for County Government
Survey:
Table 7: Response Rates for State Functions Surveyed:
Table 8: State Response Rates:
Table 9: Record Type Forms Sent to Local Government Officials, by
Functional Area:
Figures:
Figure 1: Types of Public Records Displaying SSNs Most Often Cited by
State Offices:
Figure 2: Percent of Local Government Records with SSNs Available to
the Public, by Function:
Figure 3: Percent of Counties in Which Specific Publicly Available
Records Contain SSNs:
Figure 4: Percent of Local Government Records with SSNs, by Reason for
Collecting or Using SSNs:
Figure 5: State Agency Practices for Storing Public Records That
Display SSNs:
Figure 6: Methods of Access to State Public Records Containing SSNs:
Figure 7: Number of State Agencies Citing Each Change to SSN Access for
at Least One Record Type:
Figure 8: Percent of Counties Giving Access to Public Records
Displaying SSNs, by Method of Access:
Abbreviations:
CMS: Centers for Medicare and Medicaid Services:
DoD: Department of Defense:
MCD: minor civil division:
NACO: National Association of Counties:
NARA: National Archives and Records Administration:
OMB: Office of Management and Budget:
SSA: Social Security Administration:
SSN: Social Security number:
UCC: Uniform Commercial Code:
VA: Department of Veterans Affairs:
United States Government Accountability Office:
Washington, DC 20548:
November 9, 2004:
The Honorable E. Clay Shaw:
Chairman:
Subcommittee on Social Security:
Committee on Ways and Means:
House of Representatives:
Dear Mr. Chairman:
The Social Security number (SSN) is used by federal, state, and local
government agencies for a myriad of purposes, including data sharing,
research, and the administration of programs that deliver services and
benefits to the public. In the course of public business, government
agencies create, collect, or maintain many records or documents that
contain SSNs, many of which are often made available to the public in
their entirety for inspection. These governments may also handle SSNs
that, while not exposed in public records, are nevertheless subject to
public view because they are printed on individual eligibility and
identification cards. While federal and state laws may authorize or
require the use of SSNs, there is no single federal law governing their
handling by all levels and branches of government or restricting their
display to the public. State laws also vary in regulating SSN use and
exposure to public view.
While the use of SSNs can be extremely beneficial to the public sector,
SSNs are also a key piece of information used in identity thefts,
including creating false identities for financial misuse or for
assuming another individual's identity. The widespread use and
retention of SSNs by both the public and private sectors may provide
opportunities for criminals to easily obtain and misuse this personal
information. In particular, the availability of individuals' SSNs in
public records has raised concern over how this personal information
might be misused and how it should be protected. Historically, the
general public has gained access to public records by visiting the
offices that maintain them--this offered practical limits on the volume
of SSNs that could be disclosed. Today, however, the growth in
electronic record keeping and the increasing availability of such
information in volume over the Internet have heightened concern about
misuse, particularly in view of the rise in identity thefts. We
previously reported in 2002 that few government entities that display
SSNs in public records were making them available on their Web sites,
but some were considering doing so or expanding the volume and type of
such posting.[Footnote 1]
In light of the potential for increasing exposure, theft, and misuse of
SSNs, you asked us to identify common methods of storing public
documents with SSNs and to determine the extent to which the public has
access to them. To do this, we addressed three questions: (1) To what
extent are SSNs visible in records that are made available to the
public? (2) For what purpose do governments collect SSNs in records
that display them to the public? (3) How are these records stored and
what methods can the public use to access them? In addition to looking
at public records, we examined the practices of several federal
executive branch agencies pertaining to the display of SSNs on health
insurance cards and other identification cards issued under their
authority.
To answer these questions, we conducted research at federal, state, and
local levels of government. To obtain information at the federal level,
we reviewed the Privacy Act and other related statutes and conducted
personal interviews with officials of 10 federal agencies. Data
gathering at the state level included a Web-based survey to state
agency heads that oversee eight pre-selected programs or functions in
all 50 states and the District of Columbia (D.C.). In a previous GAO
survey, these programs or functions were identified as frequent users
of SSNs and likely to have public records.[Footnote 2] They included
(1) human services, (2) health and vital statistics, (3) selected
professional licensing offices, (4) law enforcement, (5) the judiciary,
(6) corrections, (7) public safety, and (8) labor. At the state level,
our survey of the judiciary consisted of the office of the State Court
Administrator in each state. We also conducted a survey of various
local government officials within a probability sample of 200 counties
across the United States, allowing us to generalize to the population
of U.S counties. At the local level, we surveyed (1) courts, (2) health
departments, (3) law enforcement, (4) recording officials,[Footnote 3]
(5) social services, (6) tax assessors, and (7) voter registrars. At
the local level, our survey of the judiciary included trial courts and
courts of limited jurisdiction operating in the counties in our sample.
The state survey results are based on responses from 338 out of 542
state agencies, with responses from all 50 states and D.C. The local
government survey results are estimated with a response rate of about
81 percent.[Footnote 4] The questions asked in each survey are listed
in appendix II. We conducted our work between March 2003 and September
2004 in accordance with generally accepted government auditing
standards. For additional information on our methodology, see appendix
I.
Results in Brief:
We found that SSNs are widely exposed to view in a variety of public
records, particularly those held by state and local governments, and
appear in some public record nearly everywhere in the nation.
Specifically, agencies in 41 states and the District of Columbia
reported that SSNs are accessible in at least some of the public
records they hold and a few reported this to be the case for as many as
10 or more different records. Additionally, we estimate that more than
three-quarters of U.S. counties hold at least one type of record that
displays SSNs, which has implications for the 94 percent of the U.S.
population that we estimate live in those counties.[Footnote 5] While
we found SSNs displayed in a great variety of state and county records,
they were most often displayed in court and property records. On the
other hand, SSNs in records held by federal executive branch agencies
are protected under the Privacy Act of 1974 and are, therefore, not
generally available to the public. However, we found that SSNs are
sometimes available in federal court records.
State and local government respondents to our survey commonly cited
identity verification as a reason for collecting or using SSNs in
records that are available to the public, but some agencies reported
having no use for the number. State agencies also reported collecting
the SSN to facilitate matching with other records or data--the second-
most cited purpose among states. For local government offices, the
second most frequently cited reason was to meet state legal or
regulatory requirements. However, some state and local offices said
they had no specific use for the SSN in a particular type of record,
but that documents submitted to their offices often contain them. The
federal courts routinely collect SSNs for records in bankruptcy filings
in order to ascertain the identities and holdings of debtors. SSNs are
also routinely collected by the federal courts for Social Security
claims cases. According to the Administrative Office of the U.S.
Courts, however, due to privacy concerns Social Security cases are not
available electronically to the public.
Public documents with SSNs are stored in a multiplicity of ways, and we
found that public access methods are highly variable. State government
offices tend to store such records electronically, while most such
local government records are stored on microfiche or microfilm.
However, for both levels of government, inspection of paper copies is
the most commonly available method for public access. Few state
agencies make records containing SSNs available on the Internet.
However, we estimate that local government offices in as many as 15 to
28 percent of counties do make SSNs available through the Internet.
Still, few state or local offices reported plans to put additional
records on the Internet. Additionally, some state and local offices
have begun restricting access to SSNs in public records overall.
Moreover, at the federal level, the federal court system has recently
taken action to restrict access to SSNs in their public records.
In our work, we also found another kind of exposure in the form of
identity cards issued by federal agencies to individual employees,
program beneficiaries and military personnel. Though not visible
through public databases, these SSNs are nevertheless visible on the
identity cards issued to millions of individuals by federal agencies.
The display of nine-digit SSNs on such cards, which may need to be
carried and must often be disclosed, puts cardholders at risk for
identity theft due to the increased potential for accidental loss,
theft, or visual exposure. Currently, this practice involves an
estimated 42 million Medicare cards, 8 million Department of Defense
identification cards, as well as some insurance cards, and 7 million
Department of Veterans Affairs identification cards. Approximately
830,000 federal employees also carry health insurance cards, issued as
part of the Federal Employees Health Benefits Program (FEHBP), which
display the bearer's full SSN. Three federal agencies, the Office of
Personnel Management (which administers the FEHBP), Department of
Defense, and Veterans Affairs, are taking action to remove SSNs from
health insurance cards or some identification cards in recognition that
the exposure of individuals' SSNs may increase their vulnerability to
identity theft. However, there is no single federal policy governing
SSN display on such cards.
Given the potential for misuse created by the display of SSNs on cards,
therefore, we are recommending that the Office of Management and Budget
identify all those federal activities that require or engage in the
display of nine-digit SSNs on health insurance, identification, or any
other cards issued to federal government personnel or program
beneficiaries, and devise a governmentwide policy to ensure a
consistent approach to this type of display. We provided a draft of
this report to the Administrative Office of the United States Courts,
the Centers for Medicare and Medicaid Services, the Department of
Defense, the National Archives and Records Administration, the Office
of Management and Budget, the Office of Personnel Management, the
Social Security Administration, and the Department of Veterans Affairs
for comment. Officials at each agency confirmed that they had reviewed
the draft and generally agreed with its findings and recommendation.
See appendixes VI through VIII for the formal written comments from the
Department of Defense, the Office of Personnel Management, and the
Social Security Administration respectively.
Background:
Because the SSN is unique for every individual, both the public and
private sectors increasingly use it as a universal identifier. It is
particularly useful to government for data matching or identity
verification to ensure that individuals are eligible for program
benefits or services. Though the use of SSNs by government entities is
often mandated or authorized by law, there is no one law that regulates
the overall use of SSNs by all levels and branches of government, and
state laws pertaining to SSN display vary in terms of the restrictions
they impose on both use and disclosure. Due to the pervasive use of
SSNs, individuals are routinely asked to disclose their SSNs along with
other personal, identifying information, for numerous purposes. In some
instances where individuals provide their SSNs to government entities,
documents containing the SSN are routinely made available to the public
for inspection.
Generally, the overall use and disclosure of SSNs by the federal
government is restricted under the Privacy Act, which, broadly
speaking, seeks to balance the government's need to maintain
information about individuals with the rights of individuals to be
protected against unwarranted invasions of their privacy. Section 7 of
Public Law 93-579 requires that any federal, state, or local government
agency, when requesting an SSN from an individual, tell individuals
whether disclosing their SSN is mandatory or voluntary, cite the
statutory or other authority under which the request is being made, and
state what uses it will make of the individual's SSN.[Footnote 6] Based
on a survey for prior work, we reported that while nearly all
government entities we surveyed collect and use SSNs for a variety of
reasons, many of these entities reported they do not provide
individuals the information required under this statute when requesting
their SSNs.[Footnote 7] Further, it is unclear who has responsibility
for overseeing these requirements placed on state and local
governments.
The growth in the use of SSNs is important to individual SSN holders
because these numbers, along with names and birth dates, are among the
three personal identifiers most often sought by identity thieves, and
recent statistics indicate that the incidence of identity theft is
growing. The widespread disclosure of SSNs in public records has raised
concern because it can put individuals at increased risk for identity
theft. The passage of identity theft legislation by the federal
government and state governments indicates that this type of crime is
widely recognized as a serious problem. Some of these laws include
limits or restrictions on the display of SSNs, and government agencies
have taken other measures to restrict the exposure of SSNs as well. For
instance, most states have modified their policies on placing SSNs on
state drivers' licenses, some prohibit the use of SSNs as a student
identification number, and others have removed SSNs from checks and
benefit statements. These actions suggest that the risk of SSN exposure
is also widely recognized.
As governments move increasingly to electronic record keeping, access
to documents that include Social Security numbers has become easier. To
the extent that such records are available through the Internet, ease
of access can increase exponentially. The growth of electronic record
keeping has, in fact, made it easier for some agencies to provide or
even sell their data in bulk. In our previous research, a few
government agencies and courts reported to us that they were also
considering the prospect of expanding the volume and type of public
records that would be available on their Web sites. Currently,
congressional lawmakers are considering legislation to curtail such
exposures, looking at both public and private sector uses.
Not all records held by government or public agents are "public" in
terms of their availability to any inquiring person. Governments hold
many records that are not generally available and other records that
are protected from public access. For example, adoption records are
generally sealed. Personnel records are often not readily available to
the public, although newspapers may publish the salaries of high,
elected officials. Furthermore, governments may release portions of
records but protect sensitive information within them, which includes
Social Security numbers. Treatment of similar types of records varies
among federal, state, and local governments. Furthermore, there is no
common definition of public records. For this report, however, we refer
to public records as those records generally made available to the
public in their entirety for inspection by a federal, state, or local
government agency. Such documents are typically accessed in a public
reading room, clerk's office, or on the Internet.
In our previous review of government use of SSNs, we found that they
are prevalent in records held by government agencies, some of which
were available to the public.[Footnote 8] We also learned that courts
at all three levels of government maintain public records containing
SSNs, such as divorce decrees, child support orders, and bankruptcy
cases. At that time, some officials who maintained these records told
us their primary responsibility was to preserve the integrity of these
records rather than protect the privacy of the individual SSN holder.
However, we also found that some agencies were trying to better
safeguard the SSN by using innovative approaches, such as by modifying
their processes or their forms. Some agencies and courts also reported
limiting the practice of placing public records containing SSNs on Web
sites. The most far-reaching efforts we identified took place in states
that had established statewide policies and procedures. However, this
research focused, in general, on how and why governments use SSNs, and
did not examine in detail, the extent to which SSNs are exposed to the
general public and potentially available for misuse.
SSNs Are Widely Exposed in a Variety of Public Records Held by States,
Local Jurisdictions, and Courts, but Less Exposed in Federal Records:
We found that SSNs are widely exposed to public view in state and local
records, but less so in federally held records. Specifically, 41 states
and the District of Columbia reported displaying SSNs in public
records, and we estimate that over three-quarters of counties do so as
well. The number and type of records in which SSNs are displayed varies
greatly for both states and counties, but they are most often found in
court records and local property records. For federal executive branch
agencies, records are covered by the Privacy Act of 1974, which
generally prohibits disclosure of SSNs and other personal information.
However, we found that SSNs are available in some federal court
records.
Most States Display SSNs in at Least Some Public Records, but the Types
of Records Vary:
According to our survey, most states maintain at least one type of
public record that reveals individual SSNs. Agencies in 41 states as
well as the District of Columbia reported holding at least one type of
public record that shows the SSN. This may understate their exposure,
however, given that we received responses from only 62 percent of the
state agencies we surveyed. Nevertheless, we received responses from
agencies in every state. The number of these reported records ranged
from 1 to 9 for most states, but was much higher for a few states. (See
table 1.) (Appendix III provides a complete list of state and state
function response rates[Footnote 9]).
Table 1: Availability of Public Records Containing SSNs by Number of
States:
In this many states: 24;
This many types of public records contain SSNs: 1 - 4.
In this many states: 11;
This many types of public records contain SSNs: 5 - 9.
In this many states: 6;
This many types of public records contain SSNs: 10 - 19.
In this many states: 1;
This many types of public records contain SSNs: 20 or more.
Source: GAO survey of state agencies.
Note: Out of 338 agencies that responded to our survey, 90 have at
least one type of public record in which SSNs are openly displayed. Our
responses also show that in 9 states, SSNs are not shown in any public
records. However, since we did not receive responses from all state
agencies we surveyed, SSNs could be available through public records in
these 9 states.
[End of table]
Among the types of records reported by the 338 state agencies
responding, we found no one public record in which the SSN was always
displayed. The most frequently cited, however, were those held by state
courts. These ranged from criminal proceedings and litigation and civil
case files to traffic records and records of judgments. (See fig. 1.)
Appendix IV shows how state agencies responded to our question on
whether SSNs are displayed in public records.
Figure 1: Types of Public Records Displaying SSNs Most Often Cited by
State Offices:
[See PDF for image]
Note: Results based on responses from 90 agencies in 41 states and the
District of Columbia that have at least one type of public record in
which SSNs are openly displayed, out of 338 total responses.
[End of figure]
More Than 75 Percent of U.S. Counties Hold Some Public Records That
Display SSNs:
We estimate that individuals' SSNs are displayed in some public records
in 80 to 94 percent of U.S. counties. While not everyone would be
identified in such records, we estimate that this exposure could
potentially affect any one of the estimated 91 to 97 percent of the
U.S. population that lives in these counties.[Footnote 10]
According to our survey, the county records in which SSNs are most
often revealed are those held by recorders and court clerks. (For a
description of the types of records held by each program area see app.
V.) Specifically, we estimate that 58 to 68 percent of records held by
courts and 50 to 68 percent held by recording offices contain publicly
accessible SSNs, while only 5 to 9 percent of records held by all other
functions included in our survey contain SSNs.[Footnote 11] Figure 2
shows our estimates of the percent of records that display SSNs to the
public held by different types of local government offices.
Figure 2: Percent of Local Government Records with SSNs Available to
the Public, by Function:
[See PDF for image]
Note: The 95 percent confidence interval is within +/-6 percent, except
for recording officials, for which it is +/-9 percent.
[End of figure]
Courts and recording offices hold a substantial variety of records. For
example, courts hold criminal proceedings, civil cases files, and
traffic records, among others. Recorders also maintain a variety of
records, including many concerning property ownership. We estimate that
80 to 94 percent of U.S. counties have publicly available court or
property ownership records with SSNs. Specifically, SSNs are available
to the public in records of criminal proceedings in 44 to 64 percent of
counties and in divorce records in 12 to 26 percent of counties--two
kinds of records that are often held by courts. SSNs are also displayed
in some other types of records--including, military discharge records
and Uniform Commercial Code (UCC) filings.[Footnote 12] Figure 3 shows
the percent of counties in which specific types of records display SSNs
to the public.
Figure 3: Percent of Counties in Which Specific Publicly Available
Records Contain SSNs:
[See PDF for image]
Note: The 95 percent confidence interval is within +/-10 percent.
[End of figure]
While we know of no particular type of record relevant to all
individuals in a given county, there are some records that may pertain
to a large number of residents. These would be records that document
activities or transactions many people engage in--for instance, home
mortgage records or voter registrations.
To illustrate the potential for an individual's SSN to be identified in
a public record, we have estimated the percent of the population that
lives in counties in which SSNs are available in certain types of
records. For instance, we estimate that 27 to 41 percent of the
population lives in counties in which SSNs are available to the public
in traffic records. Further, from 49 to 63 percent of the population
lives in counties in which SSNs are available in mortgage and real
property transfer records, and from 16 to 28 percent lives in counties
in which SSNs are available in divorce records.
Under the Law, SSNs Are Generally Not Available to the Public in
Federal Executive Records, but They Can Be Viewed in Some Federal Court
Records:
While the federal government compiles a wide range of information on
individuals that often includes SSNs, the Privacy Act of 1974 may
prohibit their disclosure, along with other personal information,
without the consent of the individual.[Footnote 13] Specifically, SSNs
in record systems--specific groups of records--held by federal
executive agencies are generally not available to the public.[Footnote
14] SSNs that are not held in a system of records, however, may not be
governed by any other law or regulation and, therefore, may be exposed
on a limited basis. However, there was no way to ascertain where they
might be or the degree of any public access. Nevertheless, officials we
interviewed in 5 selected agencies reported that they were not aware of
any records maintained by their agencies--in a system or otherwise--
that display SSNs to the public.
Federal court records are generally available to the public, but the
courts have supervisory power to withhold certain information from
public examination.[Footnote 15] Statutes also require records
disclosure in some instances.[Footnote 16] Social Security numbers are
sometimes found in these records.[Footnote 17] According to officials
of the Administrative Office of the U.S. Courts, SSNs are available in
certain types of records because the SSNs are required by law.
Occasionally, but not routinely, SSNs are available in other files
throughout the federal court system when attorneys of record include
this information in documents filed with the court. In the last 2
years, however, the Judicial Conference of the United States, which
establishes policy for the federal judiciary, revised federal policy in
bankruptcy cases so that only the last four digits of any SSN will be
visible to the general public in new record entries.[Footnote 18]
Identity Verification Is the Most Common Use of SSNs in Public Records:
State and local government respondents to our survey reported
frequently using SSNs in public records to verify identities or to meet
state legal requirements, but some agencies said they had no need for
them.[Footnote 19] For state agencies, the second most frequently cited
purpose for using SSNs was to match information in other records or
databases. Among local government agencies the second most frequently
cited reason was to comply with state law or regulations. However, some
state and local offices reported that they had no specific use for the
SSNs in certain records, although they were often contained in
documents submitted to their offices. The federal courts reported
routinely collecting SSNs to ascertain the identities and holdings of
debtors involved in bankruptcy filings. Courts also reported routinely
collecting SSNs for Social Security claims cases.
In State Public Records the SSN is Most Often Collected or Used for
Identity Verification:
Identity verification was the most frequent reason given by our state
survey respondents for collecting or using SSNs that are shown in
public records. Fifty-four state agencies representing 30 states cited
this reason. Ten agencies, representing 8 states, indicated there was
no specific reason for collecting or using the SSN in a particular type
of public record. Table 2 shows the reasons cited for collecting or
using SSNs in public records and the number of state agencies that gave
each reason.
Table 2: Reasons Reported by State Agencies for Collecting or Using
SSNs That Are Displayed in Public Records:
Reasons for collecting or using SSN: Identify verification;
Number of state agencies: 54.
Reasons for collecting or using SSN: Matching with other records or
data;
Number of state agencies: 40.
Reasons for collecting or using SSN: Directed by state law or
regulation;
Number of state agencies: 36.
Reasons for collecting or using SSN: Data exchange or sharing;
Number of state agencies: 26.
Reasons for collecting or using SSN: Directed by federal law or
regulation;
Number of state agencies: 21.
Reasons for collecting or using SSN: Used as file or record number;
Number of state agencies: 13.
Reasons for collecting or using SSN: Benefit coordination or credit
check;
Number of state agencies: 13.
Reasons for collecting or using SSN: Other;
Number of state agencies: 30.
Reasons for collecting or using SSN: No specific use;
Number of state agencies: 10.
Source: GAO survey of state agencies.
Note: Out of 90 state agencies that provided responses to our question
on reasons and uses for collecting SSNs. Respondents were asked to
provide reasons for each record type they maintained and were allowed
to check more than one reason or use for each record type.
[End of table]
Other reasons state agencies gave were primarily to collect fines,
fees, or judgments, and because the SSNs were already included in
documents that became part of the public records. Some of these
respondents gave specific examples of how the SSN is used for identify
verification or benefits determination. Three respondents noted that
SSNs are used to facilitate investigations of wrongdoing.
SSNs in Local Government Public Records Are Most Often Used for
Identity Verification, but Many Recording Offices Receive Records with
SSNs They Do Not Need:
SSNs in local government public records are most often collected or
used for identity verification. After identity verification, other
common reasons include complying with state laws and regulations and
matching with other records. Additionally, quite a few offices maintain
public records that contain SSNs for which they have no use. Figure 4
shows reasons that SSNs are in local public records and our estimates
for the percent of such records that contain SSNS for each purpose.
Figure 4: Percent of Local Government Records with SSNs, by Reason for
Collecting or Using SSNs:
[See PDF for image]
Note: The 95 percent confidence interval is within +/-7 percent.
Respondents were asked to provide reasons for each record type they
maintained and were allowed to check more than one reason or use for
each record type.
[End of figure]
Reasons for collecting SSNs in public records varied across different
functional areas at the county level. Among local courts, identity
verification is the single most common use of SSNs in public records,
while recording offices collect or use SSNs in public records to comply
with state laws or regulations more often than any other specific
purpose. Among all other functions, SSNs are most frequently used for
identity verification, matching with other records, and complying with
state laws or regulations. Recorders also frequently maintain records
that contain SSNs for which they have no use. On the basis of our
survey, we estimate that 25 to 51 percent of records with SSNs held by
recording offices contain the number for no specific purpose. In
addition, the survey responses of some recording officials indicated
that SSNs are not required or requested by their offices, but they may
appear in records filed in their offices nonetheless. Some respondents
indicated that their job is to maintain the record only--they cannot
amend or change it. Table 3 is a sample of responses from those who
checked the "other" option to the question asking why SSNs are
collected or used in specific types of public records. (For the
complete survey question and response categories, see appendix II.)
Table 3: A Sample of Responses from County Officials Who Selected
"Other" in Response to "Why does your office collect or use SSNs" for
Specific Types of Records:
Form: Records of criminal proceedings;
Function: Court clerk;
Survey response: It is provided to us; we don't ask for it.
Form: Records of criminal proceedings;
Function: Court clerk;
Survey response: We don't want them - they just put them on.
Form: Records of criminal proceedings;
Function: Court clerk;
Survey response: Other agencies provide - the court does not collect.
Form: Litigation and civil case files;
Function: Court clerk;
Survey response: Attorney places # on complaint & is not used by court
in any way.
Form: Litigation and civil case files;
Function: Court clerk;
Survey response: SSNs are part of records file with us by parties to
the action.
Form: Estate and inheritance records;
Function: Court clerk;
Survey response: We do not screen public records for SSNs & remove. If
there, we leave them.
Form: Estate and inheritance records;
Function: Court clerk;
Survey response: We do not request the information, attorneys add it to
some forms.
Form: Mortgage and real property transfer records;
Function: Recorder;
Survey response: Not required in Maine, but listed on some documents
prepared out of state.
Form: Mortgage and real property transfer records;
Function: Recorder;
Survey response: SSNs are added by the mortgage companies.
Form: Mortgage and real property transfer records;
Function: Recorder;
Survey response: Documents are presented for recording with the # on
them. We are not authorized to change.
Form: Mortgage and real property transfer records;
Function: Recorder;
Survey response: We do not use or collect. The lender chooses to put
the SSN on the document.
Form: Records of property liens and other judgments;
Function: Recorder;
Survey response: We do not require SSNs for our purposes.
Form: Records of property liens and other judgments;
Function: Court clerk;
Survey response: Must record as presented.
Form: Records of property liens and other judgments;
Function: Recorder;
Survey response: We do not collect SSN. If they are on the document
they are recorded.
Form: Records of property liens and other judgments;
Function: Recorder;
Survey response: Preparer of instrument does not want to remove the #
from the instrument.
Form: Records of property liens and other judgments;
Function: Court clerk;
Survey response: Documents are received with SSN and we cannot alter or
change any document.
Form: Military discharge records;
Function: Recorder;
Survey response: The SSN is on the document when it comes into the
office.
Form: Military discharge records;
Function: Recorder;
Survey response: Already on record when presented.
Form: Military discharge records;
Function: Recorder;
Survey response: We do not use or collect SSNs - they are put on
document by government.
Form: Child paternity records;
Function: Court clerk;
Survey response: Included in petition filed by attorney.
Form: Child paternity records;
Function: Court clerk;
Survey response: We have no control over the information people want
to disclose in pleadings.
Form: Divorce records;
Function: Court clerk;
Survey response: Documents are submitted that way.
Source: GAO survey of local governments.
[End of table]
Federal Executive and Judicial Branches Collect and Use SSNs for
Purposes Required or Permitted by Law:
Federal agencies engage in a wide range of required or permitted uses
of SSNs, such as electronic matching of information in databases.
Various federal laws and regulations require or permit federal agencies
to collect and use SSNs when administering federal programs. However,
as noted above, due to Privacy Act provisions, in most cases these SSNs
are not available to the public. Concerning the federal judiciary, SSNs
are generally required for bankruptcy and Social Security claims cases.
SSNs are generally not required with regard to other civil or criminal
cases.
Public Documents with SSNs Are Stored in a Multiplicity of Formats, but
Hard Copy Is Still the Most Widely Available Form of Public Access:
Storage methods and forms of public access to records with SSNs vary
somewhat among the different levels of government, but hard copy is the
most common form of access for the public, and some agencies have begun
to reduce SSN exposure. State government offices tend to store such
records electronically, while most such local government records are
stored on microfiche or microfilm. However, for both these levels of
government, inspection of paper copies is the most commonly available
method for public access to such records. Few state agencies make them
available on the Internet. In counties, however, we estimate that
offices in as many as 15 to 28 percent--several hundred--do so. For the
future, however, few state or local offices reported any plans to place
additional records on the Internet. Some state and local offices
reported that in recent years they had begun to restrict access to SSNs
in public records. At the federal level, the National Archives stores
many federal agency documents, with access restricted by law. For its
part, the federal court system has recently taken action to restrict
access to SSNs in its public bankruptcy records, including those on the
Internet.
While State Public Records Containing SSNs Tend to be Stored
Electronically, Public Access Is Usually Limited to Hard Copies:
State agencies responding to our survey generally store public records
that display SSNs electronically. Electronic databases or indexes was
the most frequently cited storage method. Microfiche or microfilm and
computer usable media such as DVDs, CD-ROMs, diskettes, or tapes were
also frequently cited. Figure 5 shows the number of state agencies
using each storage method we asked about in our survey.
Figure 5: State Agency Practices for Storing Public Records That
Display SSNs:
[See PDF for image]
Note: Respondents could check more than one storage method for each
record type they maintain. Based on responses from 90 state agencies
that reported SSNs are available in public records they maintain out of
338 total survey respondents.
[End of figure]
Other electronic formats cited were primarily references to agency or
function specific data systems and general references to digital
imaging. Some respondents to this option also noted that records were
only maintained in paper formats.
Many state offices also use more than one method to store the same type
of records. This pattern could be due to retention of older records in
noncomputerized formats such as microfiche/film and placement of newer
records into computerized formats, rather than having a single record
available in multiple formats. Table 4 shows the extent of this
practice.
Table 4: State Office Use of Multiple Storage Methods for Specific
Types of Records Containing SSNs:
Type of public record: Records of criminal proceedings;
Number of state agencies: 1 storage method: 5;
Number of state agencies: 2 storage methods: 2;
Number of state agencies: 3 storage methods: 4;
Number of state agencies: 4 storage methods: 2;
Number of state agencies: 5 or more storage methods: 5.
Type of public record: Litigation and civil case files;
Number of state agencies: 1 storage method: 7;
Number of state agencies: 2 storage methods: 1;
Number of state agencies: 3 storage methods: 4;
Number of state agencies: 4 storage methods: 2;
Number of state agencies: 5 or more storage methods: 3.
Type of public record: Traffic records;
Number of state agencies: 1 storage method: 5;
Number of state agencies: 2 storage methods: 2;
Number of state agencies: 3 storage methods: 2;
Number of state agencies: 4 storage methods: 1;
Number of state agencies: 5 or more storage methods: 3.
Type of public record: Records of judgments;
Number of state agencies: 1 storage method: 4;
Number of state agencies: 2 storage methods: 1;
Number of state agencies: 3 storage methods: 3;
Number of state agencies: 4 storage methods: 0;
Number of state agencies: 5 or more storage methods: 3.
Type of public record: Records of property liens and other judgments;
Number of state agencies: 1 storage method: 3;
Number of state agencies: 2 storage methods: 1;
Number of state agencies: 3 storage methods: 3;
Number of state agencies: 4 storage methods: 2;
Number of state agencies: 5 or more storage methods: 1.
Type of public record: UCC filings;
Number of state agencies: 1 storage method: 5;
Number of state agencies: 2 storage methods: 2;
Number of state agencies: 3 storage methods: 5;
Number of state agencies: 4 storage methods: 2;
Number of state agencies: 5 or more storage methods: 1.
Type of public record: Death records;
Number of state agencies: 1 storage method: 3;
Number of state agencies: 2 storage methods: 5;
Number of state agencies: 3 storage methods: 6;
Number of state agencies: 4 storage methods: 0;
Number of state agencies: 5 or more storage methods: 1.
Type of public record: Divorce records;
Number of state agencies: 1 storage method: 4;
Number of state agencies: 2 storage methods: 1;
Number of state agencies: 3 storage methods: 4;
Number of state agencies: 4 storage methods: 1;
Number of state agencies: 5 or more storage methods: 2.
Type of public record: Business or professional licenses;
Number of state agencies: 1 storage method: 2;
Number of state agencies: 2 storage methods: 4;
Number of state agencies: 3 storage methods: 3;
Number of state agencies: 4 storage methods: 1;
Number of state agencies: 5 or more storage methods: 0.
Source: GAO survey of state agencies.
Note: Based on responses from 90 state agencies that reported SSNs are
available in public records they maintain--out of 338 total survey
respondents.
[End of table]
While state agencies generally store most public records displaying
SSNs electronically, in most cases, members of the public are not able
to access the records electronically. Despite reliance on electronic
storage methods, based on our survey responses, walk-in inspection of
paper copies and mail requests are the most commonly available forms of
access to state public records containing SSNs. Fifty-four state
agencies--out of 90 where public records display SSNs--reported these
were the only way for the public to access such records. Comparatively
few state agencies responding to our survey provided Internet access to
records containing SSNs. In most offices where it is available, a fee
or user registration is required. Of those offices that make records
available on the Internet, more reported making court records and UCC
filings available than any other type of record. Figure 6 compares the
extent of Internet access with walk-in inspections and on site
electronic databases.
Figure 6: Methods of Access to State Public Records Containing SSNs:
[See PDF for image]
Note: Based on responses from 90 state agencies that reported SSNs are
available in public records they maintain--out of 338 total
respondents. Respondents could check more than one access method for
each record type they maintain.
[End of figure]
Based on their responses to our survey, state agencies are not planning
to significantly expand Internet access to public records that show
SSNs. Only 4 state agencies indicated plans to make such records
available on the Internet, and one agency plans to remove them from
Internet access. Three agencies plan changes in Internet access. One
said that a state law, with limited exceptions, barred the release of
SSNs held by any state government entity. Another agency plans to
charge a fee for Internet access to records it maintains. The third
agency plans to remove SSNs and place records on the Internet:
Our survey results show that state offices have recently taken some
measures to change the way they display or share SSNs in public
records. Again, because of the number of nonrespondents, the results
may not account for all such measures. As figure 7 shows, state
agencies most often have either redacted--covered or otherwise hidden
from view--SSNs from public versions of records or restricted access.
Figure 7: Number of State Agencies Citing Each Change to SSN Access for
at Least One Record Type:
[See PDF for image]
Note: Based on responses from all 338 agencies that completed the
survey. Of that number, 275 agencies responded that no changes were
made for at least one record type they maintain. Total counts exceed
338 because some agencies provided responses for more than one record
type. Therefore, some agencies that responded no change for one record
type may have indicated a change for another record type. Respondents
could check more than one change for each record type they maintained.
[End of figure]
Specific restrictions and other actions state agencies reported taking
included blocking or removing SSNs from electronic versions of records,
allowing individuals identified in records to keep their SSNs out of
publicly available versions, replacing SSNs with alternative
identifiers, and restricting access only to individuals identified in
the records. A number of state agencies also described broader policy
changes taken by their state governments in the last 2 years.[Footnote
20] According to survey respondents, at least 8 states have enacted new
laws to restrict public disclosure of SSNs. These states, with brief
descriptions of the newly enacted laws are listed in table 5.
Table 5: Recent State Laws Restricting Public Disclosure of SSNs Cited
by Survey Respondents:
Florida; In October 2002, a law took effect making SSNs held by state
agencies, employees, or contractors confidential and exempt from
disclosure under the state's public records law and constitutional
right of access to public records. The same law also barred the
inclusion of SSNs on any document filed with a county recorder in the
state.
Nebraska; In 2002, a provision was added to the state's public records
law allowing state and local government entities to withhold the
disclosure of SSNs in the release of public records unless they are
disclosed in open court or administrative proceedings or open meetings,
or by a government entity in the course of its duties.
North Dakota; In 2003, the state added a provision to its public
records law making SSNs held by public entities confidential. They may
only be disclosed pursuant to other provisions of law.
Oregon; In 2003, two statutory provisions were enacted. The first
limited the re-disclosure by other state agencies of SSNs obtained from
motor vehicle records; the second requires the state court system to
develop a system preventing the disclosure of the SSNs of individuals
involved in divorce proceedings to the general public.
Tennessee; In 2002, the state enacted a statutory provision barring
state entities from publicly disclosing the SSNs of citizens of the
state, unless given permission by an individual citizen or required by
other provisions of state or federal law.
Texas; Numerous statutory changes were made since 2003: SSNs that are
maintained in voter registration records, marriage license
applications, or the state's central criminal history database may not
be disclosed. Individuals may have their SSNs removed from real
property records before they are filed with county clerks. SSNs of
persons employed in law enforcement in Texas cannot be disclosed, with
the exception of documents filed with county or district clerks.
However, this law also states that county clerks may not reject any
documents that do not contain SSNs for recording.
Virginia; In 2003, the state added two provisions to its law on the
disclosure or display of SSNs: The first bars the display of full SSNs
on agency-issued identification cards, student identification cards, or
license certificates issued or replaced on or after July 1, 2003; the
second bars state and local courts from posting any document containing
SSNs on court-controlled Web sites. This provision expires in July,
2005.
West Virginia; In early 2004, the state enacted two new laws affecting
SSN disclosure: The first restricted the circumstances under which SSNs
maintained in motor vehicle records could be disclosed to other
parties; the second barred state executive branch agencies from
disclosing SSNs in any records subject to the state's public records
law, and barred all state entities from disclosing to nongovernmental
entities SSNs of state employees and their dependents under the state's
public records law.
Source: GAO survey of state agencies and review of associated state
statutes.
[End of table]
We previously reported that Washington and Minnesota had enacted
comprehensive policies to restrict the display of SSNs.[Footnote 21]
Minnesota's law--the Minnesota Government Data Practices Act--among
other provisions specifically classifies SSNs collected by state and
local government agencies as nonpublic. Washington's policy was
implemented through an executive order signed by the governor in April
2000. In response, state agencies removed SSNs from forms and documents
where their display was found to be not vital to the business of the
agency. They also changed the format of certain public records to limit
disclosure of SSNs, such as recording SSNs on portions of forms or
duplicate forms that are not released to the public.
In October 2002, the Conference of Chief Justices and the Conference of
State Court Administrators issued a report (CCJ/COSCA
Guidelines)[Footnote 22] for state court systems regarding public
access to court records, which recommended that courts take various
means to protect SSNs within the court records they maintain. One
strategy discussed in the Guidelines would be for courts to have SSNs
be available in records only when viewed at a court facility. Such
records might be available electronically, but only through
workstations in a court facility. The Guidelines also suggest that
parties to a case or individuals identified in records be allowed to
request additional restrictions for good cause. Finally, the Guidelines
advise state court systems not to disclose SSNs protected by any state
or federal law.
Local Government Records with SSNs Are Most Often Stored on Microfiche
or Microfilm, but Are also Posted to the Internet:
Overall, microfiche or microfilm are the most commonly used methods of
storing local government public records that contain SSNs--38 to 52
percent of such records are stored in these manners. To a lesser
degree, county offices use DVDs and CD-ROMs, electronic text files,
portable data files, and electronic databases. We found no real
variation in the storage methods used by different functions.
Overall, the predominant methods for gaining access to local government
public records containing SSNs are by visiting an office in person to
inspect paper copies or requesting a copy through the mail. Records
containing SSNs are available in onsite electronic databases in 49 to
68 percent of counties. According to our survey, the Internet is the
least common form of access, although records with SSNs are accessible
on the Internet in 15 to 28 percent of U.S. counties. We estimate that
34 to 48 percent of the population lives in these counties. Figure 8
shows the estimates for the percent of counties in which different
methods can be used to access public records with SSNs.
Figure 8: Percent of Counties Giving Access to Public Records
Displaying SSNs, by Method of Access:
[See PDF for image]
Note: The 95 percent confidence interval is within +/-10 percent.
[End of figure]
According to our survey, few or no offices other than courts or
recording offices currently make records containing SSNs available via
the Internet. With regard to future plans, while we estimate that
offices in only 2 to 8 percent of counties plan to introduce Internet
access to records containing SSNs, this may have consequences for the
13 to 25 percent of the U.S. population that lives in those counties.
In the past 2 years, the vast majority of local government offices have
not made changes to the way they display or share SSNs in particular
records. However, we estimate that offices in 13 to 27 percent of
counties have begun redacting SSNs on copies of records provided to the
public and offices in 12 to 26 percent of counties have begun
restricting access to records containing SSNs. Some offices also have
begun using partial SSNs in public records.
Access to Many Federal Records Is Restricted, and Federal Courts Are
Removing SSNs from Their Web Sites:
Federal agencies transfer paper records containing SSNs to records
centers operated by the National Archives and Records Administration
(NARA) for storage.[Footnote 23] Access to these records remains under
the legal authority of the transferring agencies, which, as noted
previously, generally do not make SSNs accessible to the public.
According to NARA officials, NARA is considering adding electronic
records storage services to the records center program, but the same
rules of access would apply to those records.
At the end of the period in which the agency records are expected to be
needed, those that have continuing value are transferred into the
National Archives and NARA's legal custody. NARA provides public access
to archival records unless the records have access restrictions. Some
records are subject to restrictions prescribed by statute, executive
order, or by restrictions specified in writing in accordance with 44
U.S.C. 2108 by the agency that transferred the records to the National
Archives of the United States. Additionally, the Archivist of the
United States imposes general restrictions to certain kinds of
information or classes of records.
NARA has many series of federal agency records in its legal custody
that contain SSNs. NARA officials told us that it has two broad
categories of archival records with SSNs: (1) name retrievable records
and (2) operations records that are not name retrievable.[Footnote 24]
NARA is unable to screen the latter records for SSNs unless the records
must be screened for another restriction. In response to requests for
name retrievable records made under the Freedom of Information Act,
NARA screens the records and redacts SSNs (if the individual is not
deceased) prior to public disclosure or release. NARA also masks the
SSNs of living individuals in archival databases that NARA makes
available to the public on its Internet Web site.
We discussed Judicial Conference policies and procedures pertaining to
privacy and SSNs with officials from the Administrative Office of the
U.S. Courts. They told us that the Conference has taken a number of
actions in recent years to increase privacy and reduce Internet access
to SSNs that are in federal court documents. These actions include (1)
implementing a rule for bankruptcy cases, effective December 1, 2003,
that requires SSNs, except for the last four digits, to be redacted
from electronically available (Internet) documents accessible to the
public; (2) issuing a "model local rule" for criminal cases that
eliminates SSNs from documents filed with the court, unless necessary,
and includes only the last four digits of SSNs in publicly available
paper and electronic versions of such documents; and (3) issuing
privacy policy guidance for electronically available court documents in
civil cases. Citing its bankruptcy case rule and model local rule for
criminal cases, the Conference also advises attorneys for parties
filing court documents to include only the last four digits of SSNs. In
its report, the committee that developed the policy noted that there
should be "consistent, nationwide policies in federal courts in order
to ensure that similar privacy protections and access presumptions
apply regardless of which federal court is the custodian of a
particular case file."[Footnote 25]
Millions of Federal Health Insurance and Identity Cards Display the
SSN:
Although they are not displayed in public records en masse, we found
that millions of SSNs are still subject to exposure on individual
identity cards issued under federal auspices. Although some agencies
are taking action to address this display of the SSN, we found that,
currently, an estimated 42 million Medicare cards display entire nine-
digit SSNs, as do some Department of Defense insurance cards and
approximately 8 million identification cards, as well as 7 million
Department of Veterans Affairs (VA) beneficiary cards. In addition,
approximately 830,000 federal employees carry health insurance cards
issued through Federal Employees Health Benefits Program that display
the bearer's full SSN. Such cards are used at the point of service - at
pharmacies, medical offices, or merely to enter buildings - and are
usually carried almost everywhere, circulating through many hands and
even photocopiers, increasing opportunities for the card and the SSN on
it to be stolen, copied, or even lost.
Three of four federal agencies have begun taking action to remove SSNs
from such health insurance or identification cards issued under their
auspices. In 2003, the federal Office of Personnel Management, which
handles personnel for executive branch agencies, directed all health
insurance carriers affiliated with the Federal Employee Health Benefit
Program to eliminate SSNs from insurance cards as soon as it is
operationally and financially practical. As of August 2004, about 57
percent of these insurers were using numbers others than SSNs on their
cards--this represents over 79 percent of the subscribers in the FEHBP.
The office projected that by the end of 2005 only 3.7 percent of FEHBP
subscribers will have their SSNs on their health insurance cards, as
more insurance companies have signaled their intention to replace the
SSN. Meanwhile, VA is eliminating SSNs from 7 million VA identification
cards and is replacing cards with SSNs or issuing new cards without
SSNs from 2004 through 2009, until all such cards have been replaced.
In 2004, the Department of Defense (DoD) began replacing approximately
6 million health insurance cards that display SSNs with cards that do
not display the bearer's SSN, but continues to include SSNs on
approximately 8 million military identification cards.[Footnote 26] In
addition, the Centers for Medicare and Medicaid Services (CMS), with
the largest number of cards displaying the entire nine-digit SSN, does
not plan to remove the SSN from Medicare identification cards. During
2003, CMS's Office of Financial Management, Program Integrity Group
conducted a study of identity theft issues, during which they
considered the possibility of removing SSNs from Medicare cards. CMS
officials who served on the workgroup told us that the group had
concluded that eliminating SSNs from 40 million Medicare cards would be
cost prohibitive.
The Social Security Administration (SSA), which is the issuer of Social
Security cards (displaying the bearer's SSN), addresses this
vulnerability differently than the other agencies. SSA recommends that
cards be kept in a safe place and that a person "not carry" it with
them unless it is needed "to show it to an employer or service
provider."[Footnote 27] In contrast, CMS instructs Medicare
participants to show the card whenever medical care is provided, and to
carry the card when traveling, but to keep the number as safe as they
would a credit card number.
While the Social Security Administration advises individuals to avoid
exposure of their SSN card, we found no federal policy regarding its
display on identity and insurance cards. Specifically, there is no
presidential executive order, federal law, or common federal policy in
effect. Although SSA has authority to issue policies and procedures
over the Social Security cards that it issues, it does not have
authority over how other federal agencies use and display SSNs. While
the Office of Management and Budget has issued guidance for managing
federal information resources and protecting records on individuals, it
has not provided guidance for the display of SSNs on cards. Rather, the
Centers for Medicare and Medicaid Services, the Office of Personnel
Management, VA, and DoD each have their own policies for the cards
issued under their authority.
Conclusions:
Today, the SSN has become a universal identifier; as such, it offers
government as well as the private sector an efficient way to verify the
identity and the qualifications of people for programs or activities
ranging from taxes to health benefits to worker's compensation
payments. As a single, unique number assigned to one person, the SSN
also allows for tracking that individual through more than one database
and comparing information for a variety of uses, including police work.
In short, SSNs are a lynchpin to other personal information held in a
variety of records. The extent to which they are exposed to public
view, of course, increases the likelihood that they will be misused for
inappropriate mining of personal information, violation of privacy, and
identity theft. The increased use of SSNs in both the public and
private sectors means that SSNs are more widely circulated and more
likely to appear in public records that document common life events and
transactions, such as marriages and home purchases.
The continued visibility of SSNs in public records in virtually every
corner of the country presents continued risk of widespread, albeit
small-scale, identity theft. Since the public usually obtains such
records in individual hard copies, the risk of SSN theft in large
volume from public records may be small. Indeed, a variety of
government agencies and oversight bodies appear to be taking steps to
eliminate the open display of SSNs, but there is no uniform practice or
policy at the federal, state, or local level to protect them. Such
initiatives to protect the SSN may slow its misuse, but the absence of
uniform and comprehensive policy is likely to leave many individuals
vulnerable. For example, the 15 to 28 percent of counties that we
estimate post some records with SSNs on the Internet creates a broad
vulnerability that, together with the lack of uniform protections,
makes it difficult for any one individual to mitigate. In one of our
previous reports, we recommended that a representative group of
federal, state, and local officials develop a unified approach to
safeguarding SSNs used in all levels of government and particularly
those displayed in public records. We still believe such an approach
would be constructive.
On another front, there is jeopardy in the display of SSNs on identity
and eligibility cards issued under government auspices. The cardholder
is usually required to use his or her card at the point of service--
which means a practical need to carry and display it often--thus
increasing the likelihood for accidental loss, theft, or visual
exposure. The risk this poses has been both recognized and addressed
by, among other things, prohibitions against using SSNs as student
identification numbers and policy changes concerning use of SSNs on
drivers' licenses. While we did not examine the phenomenon of SSN
display on identification cards across all federal programs, it is
clear that the lack of a broad, uniform policy allows for inconsistent,
but persistent exposure.
To address the overall problem of exposure for the SSN, congressional
lawmakers are considering legislation that would, among other things,
curtail display of SSNs in both the private and public sectors. For its
part, the public sector has already demonstrated that it is possible,
for example, to substitute another number for the SSN on displayable
cards, and link it to actual SSNs in a protected database. Given the
size of federal programs, the lack of such safeguards across all
agencies currently leaves millions of people unprotected.
Recommendation:
To address this potential vulnerability, we recommend that the
Director, Office of Management and Budget, identify all those federal
activities that require or engage in the display of nine-digit SSNs on
health insurance, identification, or any other cards issued to federal
government personnel or program beneficiaries, and devise a
governmentwide policy to ensure a consistent approach to this type of
display.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Administrative Office of the
United States Courts, the Centers for Medicare and Medicaid Services,
the Department of Defense, the National Archives and Records
Administration, the Office of Management and Budget, the Office of
Personnel Management, the Social Security Administration, and the
Department of Veterans Affairs for comment. Officials at each agency
confirmed that they had reviewed the draft and generally agreed with
its findings and recommendation. Officials from the Administrative
Office of the United States Courts, the Department of Defense, and the
Office of Personnel Management provided us with technical comments,
which we have incorporated into the report as appropriate. We received
formal comments from officials from the Department of Defense, the
Office of Personnel Management, and the Social Security Administration;
those comments are included in appendixes VI through VIII. We did not
receive formal written comments for this report from the Centers for
Medicare and Medicaid Services, the National Archives and Records
Administration, or the Department of Veterans Affairs, though officials
from each confirmed that they generally agreed. Additionally, OMB did
not provide formal written comments, but officials from OMB's Office of
General Counsel and Office of Information and Regulatory Affairs
confirmed that they generally agreed with the report and that they
would take our recommendation into consideration for future action.
We are sending copies of this report to the Director of the
Administrative Office of the U.S. Courts, the Administrator of the
Centers for Medicare and Medicaid Services, the Secretary of Defense,
the Archivist of the National Archives and Records Administration, the
Director of the Office of Management and Budget, the Director of the
Office of Personnel Management, the Commissioner of the Social Security
Administration, and the Secretary of Veterans Affairs, and appropriate
congressional committees, and other interested parties. In addition,
the report will be available at no charge on GAO's Web site at http://
www.gao.gov/.
If you have any questions concerning this report, please contact
Barbara Bovbjerg at (202) 512-7215. See appendix IX for other contacts
and staff acknowledgments.
Sincerely yours,
Signed by:
Barbara D. Bovbjerg:
Director, Education, Workforce and Income Security Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
To complete the objectives for this assignment, we collected original
information at the federal, state, and local government levels. We
reviewed previous GAO reports on Social Security numbers (SSN),
identity theft, data mining, information security, record linkage and
privacy, and related topics. In addition we reveiwed various studies of
state SSN use, privacy laws such as the Information Technology
Management Reform Act of 1996 (Clinger-Cohen Act), the Privacy Act of
1974, the Freedom of Information Act, the Family Educational Rights and
Privacy Act of 1974, Health Insurance Portability and Accountability
Act of 1996, the Computer Matching and Privacy Protection Act of 1988,
the Identity Theft and Assumption Deterrence Act of 1998, several
memoranda from the Office of Management and Budget (OMB), and other
related documents. We used different methods for selecting units of
study and for collecting data for each of the three levels of
government reviewed for this engagement. The methods used in the three
studies are detailed in the following sections.
Federal Level:
We conducted personal interviews with officials of 10 federal agencies:
the Administrative Office of the United States Courts, the Centers for
Medicare and Medicaid Services, the Department of Defense, the National
Archives and Records Administration, the Office of Management and
Budget, the Office of Personnel Management, the President's Council on
Integrity and Efficiency, the Social Security Administration, the
Department of Agriculture, and the Department of Veterans Affairs. We
selected these agencies because they have responsibility for
implementing the Privacy Act, the Freedom of Information Act, or
programs that are generally known to include SSNs.
We obtained information from six federal agencies using an interview
guide based on federal privacy laws and OMB's general and/or agency-
specific disclosure criteria. The interview guide also addressed each
agency's own privacy regulations and practices. Additional queries
dovetailed with questions asked at the state and local levels: public
access to the agencies' public records that contain SSNs, availability
of these records on the Internet, privacy and protecting records about
individuals and other issues unique to the agency. The interview guide
has face validity and was used as a talking point instrument.
Survey Development:
To gather information about public records that contain SSNs and
whether they are made available to the public at the state and local
levels, we surveyed state and local government officials in program
areas that were determined likely to maintain or collect public
records. We developed a list of questions to be used for both surveys,
although the state survey was Web-based and the county survey was
administered by mail.
The survey was designed to address questions about multiple public
records while allowing for analysis on specific types of records. To
this end, we developed a standardized two-page questionnaire, which
could be replicated for various types of public records and could be
used at both the state and the county level. In addition, the survey
design allowed for specific groupings of different types of records to
be sent to different respondents. For instance, court clerks were sent
forms concerning types of records different from those sent to public
health officials. The questionnaire include such items as accessibility
of records displaying SSNs to the public; reasons for collecting or
using SSNs in the record; formats for storing records with SSNs; plans
for changing those formats; methods by which the public can access or
view records with SSNs, including Internet usage and changes the office
has made in the past 2 years in the way records with SSNs are displayed
to the public.
We selected 35 different types of public records for our review. We
developed the list based on research we conducted on public records,
the results of a prior GAO survey concerning government use of
SSNs,[Footnote 28] expert reviewers, and pretesting of the survey
instrument. These records can be grouped in the following major
categories: court records (e.g., records of criminal proceedings, child
support/child custody, divorce, etc); law enforcement records (e.g.,
criminal arrest warrants, prison records); motor vehicle records; lien
and security interest records; vital records (birth, death, and
marriage); health records (immunizations and communicable diseases);
and "other" category which includes professional licensing, military
discharge records, and social service records among others. Appendix V
includes a full list of the 35 record types.
For the development of both the list of records types and the survey
questions, we obtained assistance from both internal and external
expert reviewers.
State Level:
Data gathering for the state level consisted of a Web-based survey to
state officials in previously identified program areas or functions in
all 50 states and the District of Columbia. These program areas,
identified in our previous work on government use of SSNs as likely to
maintain public records containing SSNs, included: (1) courts/
judiciary, (2) law enforcement, (3) human services, (4) health and
vital statistics, (5) selected professional licensing offices, (6)
labor, (7) corrections, and (8) public safety. Several steps were
involved in the preparation of and conduct of the survey. We obtained
the names and e-mail addresses of state officials in these offices from
a list used for our earlier work and updated names, telephone numbers,
and Web addresses using the "Yellow Book Leadership Directories"
provided in our Intranet. Two contractors made telephone calls to
verify the titles and names and to obtain the e-mail address of each of
the entries.
We sent a notification e-mail to each of the department heads of the
selected state agencies informing them about the survey. Within 2 weeks
of the notification, we sent an activation e-mail with the instructions
on how to access and complete the survey, including a survey link, and
a unique username and password to each selected state official.
To increase the response rate, we sent a reminder e-mail after the
activation email to those department heads that had not responded;
about 2 weeks later, we sent a second e-mail to nonrespondents.
Contractors followed-up nonrespondents with telephone calls about 2
weeks after the second reminder e-mail. The survey was available on
line from February 23, 2004, to July 31, 2004.
We surveyed 542 officials in the 50 states and the District of
Columbia. We received responses from 338 state agencies out of 542. In
12 states, we received responses from half or fewer of the agencies
surveyed. For three of the program areas, we received responses from
about half or fewer of the states with agencies serving those
functions. The response rates for three program areas that we believe
are most likely to maintain records with information about large
proportions of state residents (though not necessarily a majority of
residents) are: Courts/Judiciary-61 percent; human services-69
percent; health services and vital statistics-60 percent. These compare
with our overall response rate of 62 percent.
County Level:
We administered a questionnaire by mail to the study population of
local government officials in a two-stage probability sample designed
to reflect the population of U.S. counties. This allowed us to estimate
to the entire population of U.S. counties and to develop population-
based estimates. The program areas were: (1) courts, (2) law
enforcement, (3) public health, (4) recorders, (5) social services, (6)
tax assessment, and (7) voter registration. We developed a list of
contact information with addresses for local government officials using
address lists obtained from the National Association of Counties (NACO)
and BRB Publications, Inc., as well as the Yellowbook leadership
directory and information obtained from state and local government
websites. Address collection was done between November 2003 and
February 2004. To identify incumbent government officials in a sample
of counties, we used address lists of county government officials
purchased from BRB Publications and NACO and supplemented them with the
name and address list used in our prior work and by searching Web sites
and making telephone calls.
We sent out packets of questionnaires to 1996 officials in 200 counties
(including minor civil divisions in 24 counties). The number or type of
records mailed to each official depended on the research team's
judgment of the type of records each official would be likely to
maintain given his or her function. For example, we sent immunization
and communicable disease questionnaires to public health directors. We
provided for an "Other" type of record that respondents could fill out
for records they maintained and for which we did not supply a
questionnaire.
A few weeks after the initial survey was mailed, we sent a reminder
letter without replacement questionnaires. A week after the first
reminder letter, we began sending a second wave of reminder letters
with replacement questionnaires. While we received a completed survey
from at least one program area in each county, the response rates
within each county varied from 1 program area in a county to all
program areas. The overall response rate for the county survey was 81
percent. Response rates for each program area were courts (79 percent),
health departments (79 percent), law enforcement (80 percent),
recording officials (88 percent), social services (79 percent), tax
assessors (85 percent), and voter registrars (86 percent).
Local Government Sample Design:
We developed a U.S. county sample that would reflect the U.S.
population and allow making estimates related to persons. The
probability sample of 200 counties included 35 counties with the
largest populations with certainty and the remaining counties selected
using probability proportional to size of the population. The measure
of size used for sampling was the square root of the 2002 estimated
population; use of the square root function dampens some of the
variability in county-level population sizes (from ~100 to ~
10,000,000). To avoid having a sparsely populated county having large
influence on population-related estimates, two counties with 2002
estimated populations less than 150 are combined with neighboring
counties, using geographic information from the U.S. Bureau of the
Census's TIGER system; this is the one situation where sampling units
are not individual counties.
We determined that for the sampled counties in some states (24 total:
Connecticut (2), Maine (2), Massachusetts (2), Michigan (9), New
Hampshire (1), New Jersey (3), Wisconsin (5)), it was appropriate to
survey local government officials within subcounty units called "Minor
Civil Divisions" (MCD) because either county governments do not exist
(e.g., Connecticut and Massachusetts) or the MCD governments perform
many functions that usually are performed by county governments in
other areas. This second stage probability sample consisted of 59 MCDs
from the specified set of counties, consisting of the 11 MCDs that have
2002 estimated populations of 100,000 or more, and 48 MCDs (2 from each
of the 24 counties), selected using probability proportional to the
size of the population.
During the implementation of the survey, we identified respondents who
were not in the target population. Table 6 provides a summary of the
reasons for these out of sample respondents.
Table 6: Out of Sample Respondents and Reasons for County Government
Survey:
Reason out of sample: Duplicate address;
Number: 4.
Reason out of sample: Office closed;
Number: 2.
Reason out of sample: Duplicate because 1 official performs 2
functions;
Number: 3.
Reason out of sample: Total out of sample;
Number: 9.
Source: GAO survey of local governments.
[End of table]
In implementing our survey, we also had many respondents who completed
surveys on behalf of several offices. For instance, in some counties
and states where courts are centrally administered, we received just
one completed survey on behalf of all courts in a county or in a state.
In addition, in some states certain functions, such as social services,
are state government programs, but are administered by local or
regional offices. In some of these cases, we received one completed
survey from a state official on behalf of some or all local or regional
program offices.
Estimation and Sampling Error:
The results of the county survey were weighted to make the results
generalizable to the entire population of U.S. counties. For each
stratum, we formed estimates by weighting the data by the reciprocal of
the selection probability. The margins of error for the county survey
results varied because we made estimates for different subpopulations.
For all the estimates shown here, we are 95 percent confident that when
sampling error is considered, the results are within +/-7 percentage
points unless otherwise indicated. All population estimates based on
the survey of local government officials are for the target population
defined as local government officials in 7 program areas and courts
within a sample of 200 U.S. counties.
The survey of local government officials is subject to sampling error.
There was no sampling error for the census survey of state officials.
The effects of sampling errors, due to the selection of a sample from a
larger population, can be expressed as confidence intervals based on
statistical theory. Sampling errors occur because we use a sample to
draw conclusions about a larger population. As a result, the sample was
only one of a large number of samples of counties that might have been
drawn. If different samples had been taken, the results might have been
different. To recognize the possibility that other samples might have
yielded other results, we express our confidence in the precision of
our particular sample's results as a 95 percent confidence interval.
The 95 percent confidence intervals are expected to include the actual
results for 95 percent of samples of this type. We calculated
confidence intervals for this sample using methods that are appropriate
for the sample design used. For local government survey estimates in
this report, we are 95 percent confident that when sampling error is
considered, the results we obtained are within +/-7 percentage points
of what we would have obtained if we had surveyed officials in all of
the entire study population, unless otherwise noted.
Nonsampling Error:
In addition to sampling error, other potential sources of errors
associated with surveys, such as question misinterpretation, may be
present. Nonresponse may also be a source of nonsampling error. We took
several steps to reduce these other sources of error. We conducted
pretests of the questionnaire using a paper version with 11 incumbents
of the functions/roles selected for our review in four different
counties in three states to account for differing local government
structures and to ensure the questionnaire: (1) was clear and
unambiguous, (2) did not place undue burden on individuals completing
it, and (3) was independent and unbiased. In addition, we conducted
seven pretests with state officials in 2 states. The first six were
conducted using a paper version of the questionnaire and the final test
was conducted using the Web version to test for functionality.
After pre-testing we modified the questionnaire as needed for clarity,
respondent comprehension, and objectivity. Most of the items in the
questionnaire were closed-ended but provided for multiple responses to
each question as well as possibility for respondent comments regarding
public access to records with SSNs.
We performed our work in Washington, D.C., from March 2003 through
September 2004 in accordance with generally accepted government
auditing standards.
[End of section]
Appendix II: State and Local Government Survey Questions:
[See PDF for images]
[End of survey]
The survey of state agencies asked the same questions with one
addition: "How does your office transfer with full SSNs
to third parties." As discussed in appendix I, it was administered over
the Web. Unlike the county survey, we did not make any determinations
about the specific record types each agency might be responsible for
collecting and storing. The survey instrument included forms for each
record type included in our study. Respondents were first asked to
check the record types applicable to their agency then scroll down
through the instrument to complete the forms for those record types.
[End of section]
Appendix III: State Survey Response Rates by Function and State:
The overall response rate for the state survey was 62 percent. We
received responses from at least one agency in every state. In 37
states and D.C., we received responses from more than half of the
agencies surveyed. With regard to the specific functions we surveyed,
we received responses from about half or fewer of the states in three
functions: law enforcement, cosmetology licensing, and notary public
licensing. For 8 of the 12 functions, we received responses from 60
percent or more of the states.
Table 7: Response Rates for State Functions Surveyed:
Function: Courts/judiciary;
Total number of states where function was surveyed: 51;
Response rate (percent): 61%.
Function: Law enforcement;
Total number of states where function was surveyed: 44;
Response rate (percent): 52%.
Function: Human services;
Total number of states where function was surveyed: 51;
Response rate (percent): 69%.
Function: Health services and vital statistics;
Total number of states where function was surveyed: 47;
Response rate (percent): 60%.
Function: Labor;
Total number of states where function was surveyed: 50;
Response rate (percent): 76%.
Function: Corrections;
Total number of states where function was surveyed: 48;
Response rate (percent): 83%.
Function: Public safety;
Total number of states where function was surveyed: 30;
Response rate (percent): 57%.
Function: Medical and health professions licensing;
Total number of states where function was surveyed: 45;
Response rate (percent): 71%.
Function: Cosmetology licensing;
Total number of states where function was surveyed: 41;
Response rate (percent): 37%.
Function: Notary public licensing;
Total number of states where function was surveyed: 48;
Response rate (percent): 50%.
Function: Securities profession licensing;
Total number of states where function was surveyed: 45;
Response rate (percent): 62%.
Function: Real estate licensing;
Total number of states where function was surveyed: 42;
Response rate (percent): 64%.
Source: GAO survey of state agencies.
[End of table]
Table 8: State Response Rates:
State: Alabama;
Number of agencies surveyed in state: 11;
Response rate (percent): 91%.
State: Alaska;
Number of agencies surveyed in state: 11;
Response rate (percent): 45%.
State: Arizona;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Arkansas;
Number of agencies surveyed in state: 11;
Response rate (percent): 82%.
State: California;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Colorado;
Number of agencies surveyed in state: 12;
Response rate (percent): 50%.
State: Connecticut;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: Delaware;
Number of agencies surveyed in state: 10;
Response rate (percent): 80%.
State: District of Columbia;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: Florida;
Number of agencies surveyed in state: 9;
Response rate (percent): 89%.
State: Georgia;
Number of agencies surveyed in state: 12;
Response rate (percent): 75%.
State: Hawaii;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: Idaho;
Number of agencies surveyed in state: 11;
Response rate (percent): 82%.
State: Illinois;
Number of agencies surveyed in state: 9;
Response rate (percent): 78%.
State: Indiana;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: Iowa;
Number of agencies surveyed in state: 12;
Response rate (percent): 83%.
State: Kansas;
Number of agencies surveyed in state: 11;
Response rate (percent): 64%.
State: Kentucky;
Number of agencies surveyed in state: 11;
Response rate (percent): 36%.
State: Louisiana;
Number of agencies surveyed in state: 11;
Response rate (percent): 45%.
State: Maine;
Number of agencies surveyed in state: 12;
Response rate (percent): 50%.
State: Maryland;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Massachusetts;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Michigan;
Number of agencies surveyed in state: 9;
Response rate (percent): 44%.
State: Minnesota;
Number of agencies surveyed in state: 8;
Response rate (percent): 75%.
State: Mississippi;
Number of agencies surveyed in state: 10;
Response rate (percent): 50%.
State: Missouri;
Number of agencies surveyed in state: 12;
Response rate (percent): 58%.
State: Montana;
Number of agencies surveyed in state: 11;
Response rate (percent): 36%.
State: Nebraska;
Number of agencies surveyed in state: 9;
Response rate (percent): 67%.
State: Nevada;
Number of agencies surveyed in state: 12;
Response rate (percent): 50%.
State: New Hampshire;
Number of agencies surveyed in state: 12;
Response rate (percent): 25%.
State: New Jersey;
Number of agencies surveyed in state: 9;
Response rate (percent): 67%.
State: New Mexico;
Number of agencies surveyed in state: 12;
Response rate (percent): 58%.
State: New York;
Number of agencies surveyed in state: 11;
Response rate (percent): 36%.
State: North Carolina;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: North Dakota;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Ohio;
Number of agencies surveyed in state: 11;
Response rate (percent): 55%.
State: Oklahoma;
Number of agencies surveyed in state: 11;
Response rate (percent): 64%.
State: Oregon;
Number of agencies surveyed in state: 11;
Response rate (percent): 64%.
State: Pennsylvania;
Number of agencies surveyed in state: 11;
Response rate (percent): 45%.
State: Rhode Island;
Number of agencies surveyed in state: 8;
Response rate (percent): 50%.
State: South Carolina;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: South Dakota;
Number of agencies surveyed in state: 11;
Response rate (percent): 91%.
State: Tennessee;
Number of agencies surveyed in state: 10;
Response rate (percent): 60%.
State: Texas;
Number of agencies surveyed in state: 12;
Response rate (percent): 83%.
State: Utah;
Number of agencies surveyed in state: 11;
Response rate (percent): 82%.
State: Vermont;
Number of agencies surveyed in state: 11;
Response rate (percent): 64%.
State: Virginia;
Number of agencies surveyed in state: 12;
Response rate (percent): 83%.
State: Washington;
Number of agencies surveyed in state: 10;
Response rate (percent): 70%.
State: West Virginia;
Number of agencies surveyed in state: 11;
Response rate (percent): 91%.
State: Wisconsin;
Number of agencies surveyed in state: 8;
Response rate (percent): 63%.
State: Wyoming;
Number of agencies surveyed in state: 11;
Response rate (percent): 73%.
Source: GAO survey of state agencies.
[End of table]
[End of section]
Appendix IV: Extent of SSN Availability in State Public Records:
Record type: Records of criminal proceedings;
Number of states where records are available to the public
and SSNs are shown: 19;
Number of states where records are available to the public,
but SSN is not shown on public version: 17;
Number of states where records are not available to the public: 10.
Record type: Litigation and civil case files;
Number of states where records are available to the public
and SSNs are shown: 19;
Number of states where records are available to the public,
but SSN is not shown on public version: 17;
Number of states where records are not available to the public: 12.
Record type: Jury lists;
Number of states where records are available to the public
and SSNs are shown: 2;
Number of states where records are available to the public,
but SSN is not shown on public version: 5;
Number of states where records are not available to the public: 6.
Record type: Estate and inheritance records;
Number of states where records are available to the public
and SSNs are shown: 8;
Number of states where records are available to the public,
but SSN is not shown on public version: 3;
Number of states where records are not available to the public: 7.
Record type: Traffic records;
Number of states where records are available to the public
and SSNs are shown: 15;
Number of states where records are available to the public,
but SSN is not shown on public version: 11;
Number of states where records are not available to the public: 5.
Record type: Records of judgments;
Number of states where records are available to the public
and SSNs are shown: 15;
Number of states where records are available to the public,
but SSN is not shown on public version: 12;
Number of states where records are not available to the public: 12.
Record type: Mortgage and real property transfer records;
Number of states where records are available to the public
and SSNs are shown: 5;
Number of states where records are available to the public,
but SSN is not shown on public version: 3;
Number of states where records are not available to the public: 7.
Record type: Records of property liens and other judgments;
Number of states where records are available to the public
and SSNs are shown: 10;
Number of states where records are available to the public,
but SSN is not shown on public version: 3;
Number of states where records are not available to the public: 8.
Record type: Property ownership records;
Number of states where records are available to the public
and SSNs are shown: 3;
Number of states where records are available to the public,
but SSN is not shown on public version: 5;
Number of states where records are not available to the public: 7.
Record type: Tax assessment records;
Number of states where records are available to the public
and SSNs are shown: 3;
Number of states where records are available to the public,
but SSN is not shown on public version: 4;
Number of states where records are not available to the public: 15.
Record type: Uniform Commercial Code (UCC) filings;
Number of states where records are available to the public
and SSNs are shown: 15;
Number of states where records are available to the public,
but SSN is not shown on public version: 3;
Number of states where records are not available to the public: 0.
Record type: Birth certificates;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 8;
Number of states where records are not available to the public: 24.
Record type: Adoption records;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 2;
Number of states where records are not available to the public: 32.
Record type: Child custody records;
Number of states where records are available to the public
and SSNs are shown: 8;
Number of states where records are available to the public,
but SSN is not shown on public version: 4;
Number of states where records are not available to the public: 19.
Record type: Child paternity records;
Number of states where records are available to the public
and SSNs are shown: 6;
Number of states where records are available to the public,
but SSN is not shown on public version: 6;
Number of states where records are not available to the public: 29.
Record type: Child support records;
Number of states where records are available to the public
and SSNs are shown: 5;
Number of states where records are available to the public,
but SSN is not shown on public version: 6;
Number of states where records are not available to the public: 31.
Record type: Divorce records;
Number of states where records are available to the public
and SSNs are shown: 11;
Number of states where records are available to the public,
but SSN is not shown on public version: 6;
Number of states where records are not available to the public: 12.
Record type: Death records;
Number of states where records are available to the public
and SSNs are shown: 16;
Number of states where records are available to the public,
but SSN is not shown on public version: 7;
Number of states where records are not available to the public: 18.
Record type: Marriage licenses or applications;
Number of states where records are available to the public
and SSNs are shown: 3;
Number of states where records are available to the public,
but SSN is not shown on public version: 9;
Number of states where records are not available to the public: 13.
Record type: Name change petitions;
Number of states where records are available to the public
and SSNs are shown: 6;
Number of states where records are available to the public,
but SSN is not shown on public version: 7;
Number of states where records are not available to the public: 9.
Record type: Concealed weapons applications;
Number of states where records are available to the public
and SSNs are shown: 2;
Number of states where records are available to the public,
but SSN is not shown on public version: 4;
Number of states where records are not available to the public: 10.
Record type: Hunting or fishing licenses;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 0;
Number of states where records are not available to the public: 0.
Record type: Military discharge records;
Number of states where records are available to the public
and SSNs are shown: 2;
Number of states where records are available to the public,
but SSN is not shown on public version: 8;
Number of states where records are not available to the public: 19.
Record type: Military induction records;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 1;
Number of states where records are not available to the public: 6.
Record type: Business or professional licenses;
Number of states where records are available to the public
and SSNs are shown: 11;
Number of states where records are available to the public,
but SSN is not shown on public version: 38;
Number of states where records are not available to the public: 2.
Record type: Public utility usage records;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 1;
Number of states where records are not available to the public: 1.
Record type: Social service case files or records;
Number of states where records are available to the public
and SSNs are shown: 2;
Number of states where records are available to the public,
but SSN is not shown on public version: 5;
Number of states where records are not available to the public: 32.
Record type: Vehicle or vessel registration records;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 2;
Number of states where records are not available to the public: 6.
Record type: Voter registration records;
Number of states where records are available to the public
and SSNs are shown: 2;
Number of states where records are available to the public,
but SSN is not shown on public version: 2;
Number of states where records are not available to the public: 3.
Record type: Notary commission records;
Number of states where records are available to the public
and SSNs are shown: 5;
Number of states where records are available to the public,
but SSN is not shown on public version: 7;
Number of states where records are not available to the public: 3.
Record type: Records of communicable diseases;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 2;
Number of states where records are not available to the public: 15.
Record type: Immunization records;
Number of states where records are available to the public
and SSNs are shown: 1;
Number of states where records are available to the public,
but SSN is not shown on public version: 1;
Number of states where records are not available to the public: 20.
Record type: Records of criminal arrest warrants;
Number of states where records are available to the public
and SSNs are shown: 8;
Number of states where records are available to the public,
but SSN is not shown on public version: 12;
Number of states where records are not available to the public: 23.
Record type: Prison records;
Number of states where records are available to the public
and SSNs are shown: 6;
Number of states where records are available to the public,
but SSN is not shown on public version: 20;
Number of states where records are not available to the public: 18.
Record type: Other records or files;
Number of states where records are available to the public
and SSNs are shown: 16;
Number of states where records are available to the public,
but SSN is not shown on public version: 20;
Number of states where records are not available to the public: 12.
Source: GAO survey of state agencies.
Note: Based on responses from 338 of 542 state agencies surveyed.
[End of table]
[End of section]
Appendix V: Types of Public Records Held by Local Government Offices:
Because of variation in local governments, each type of record is not
always maintained by the same type of office across all counties.
Furthermore, program areas that are separate in some counties are
combined in others. For instance, in many counties the clerk or
recorder performs functions such as voter registration or tax
assessment, which operate independently in other counties. Due to these
variations, it is not always possible to pinpoint which office within a
county maintains a particular type of record.
Unless we had specific information indicating what records are
maintained in a specific office within a specific county, in
administering our survey to local government officials, we sent the
same set of forms (each with the same set of questions, but for a
specific type of record) to officials within each program area or
function. For example, we sent immunization and communicable disease
questionnaires to public health directors. We also provided an "Other"
record form that all respondents could fill out for records they
maintained and for which we did not supply a questionnaire. Table 9
shows the types of forms that were sent to each program area.
Table 9: Record Type Forms Sent to Local Government Officials, by
Functional Area:
Function: Court clerks;
Type of records:
* Adoption records;
* Child custody records;
* Child paternity records;
* Child support records;
* Divorce records;
* Estate and inheritance records;
* Jury lists;
* Litigation and civil case files;
* Name change petitions;
* Records of criminal proceedings;
* Records of judgments;
* Traffic records.
Function: Health department;
Type of records:
* Birth certificates;
* Death records;
* Immunization records;
* Records of communicable diseases.
Function: Law enforcement;
Type of records:
* Concealed weapons applications;
* Prison records;
* Records of criminal arrest warrants.
Function: Recording officials;
Type of records:
* Business or professional licenses;
* Hunting or fishing licenses;
* Marriage licenses or applications;
* Military discharge records;
* Military induction records;
* Mortgage and real property transfer records;
* Notary commission records;
* Property ownership records;
* Public utility usage records;
* Records of property liens and other judgments;
* Uniform Commercial Code (UCC) filings;
* Vehicle or vessel registration records.
Function: Social services;
Type of records:
* Social service case files or records.
Function: Tax assessor;
Type of records:
* Tax assessment records.
Function: Voter registrars;
Type of records:
* Voter registration records.
Source: GAO.
[End of table]
Due to the variations mentioned above, we received responses about some
types of records from more than one program area. Survey responses
concerning the following types of records were most often returned by
recording officials, but not infrequently by courts: mortgage and real
property transfer records, property ownership records, records of
property liens and other judgments, Uniform Commercial Code (UCC)
filings, divorce records, marriage licenses or applications, hunting
and fishing licenses, military discharge and induction records,
business or professional licenses, public utility usage records, notary
commissions, and vehicle or vessel registrations.
[End of section]
Appendix VI: Comments from the Department of Defense:
OFFICE OF THE UNDER SECRETARY OF DEFENSE:
4000 DEFENSE PENTAGON
WASHINGTON, D.C. 20301-4000:
PERSONNEL AND READINESS:
SEP 16 2004:
Ms. Barbara D. Bovdjerg:
Director, Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, N.W.:
Washington, DC 20548:
Dear Ms. Bovdjerg:
This is the Department of Defense (DoD) response to the GAO draft
report, "SOCIAL SECURITY NUMBERS: Governments Could do More to Reduce
Display in Public Records and Identity Cards," dated September 2, 2004
(GAO Code 130249/GAO-04-1047). Overall, DoD concurs with the report
with the following comments:
a. The report states there are approximately 2 million cards issued to
DoD personnel with the individual's Social Security Number (SSN) on the
cards. This number does not reflect the numbers the Department
previously provided to the GAO. The number provided is approximately
eight million, see enclosure.
b. The Draft Report refers to the DoD as "Defense." Suggest this should
be changed to reflect "Department of Defense."
c. The Geneva Accord requires all military personnel and civilian
personnel accompanying the Armed Forces to have an identification card
showing the owners serial number. The Department has employed the SSN
as the serial number. To remove this SSN from identification cards
would require a change to the Geneva Accord or a change to the serial
number that the Department currently employs: There are approximately
2.5 million cards issued that meet the requirements of the Geneva
Accord.
The Department appreciates the opportunity to comment on the draft
report. For questions please contact my action officer Ms. Mary Dixon
at (703) 696-7423 or Mike Butler, (703) 696-7395.
Sincerely,
Signed by:
Jeanne B. Fites:
Deputy Under Secretary of Defense:
Program Integration:
Enclosure: As stated:
[End of section]
Appendix VII: Comments from the Office of Personnel Management:
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT:
WASHINGTON, DC 20415-0001:
OFFICE OF THE DIRECTOR:
OCT 04 2004:
Barbara D. Bovbjerg, Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Bovbejerg:
I appreciate the opportunity to provide comments to your draft report,
GAO-04-1047, "Social Security Numbers: Governments Could do More to
Reduce Display in Public Records and Identity Cards."
I am very proud of the Office of Personnel Management's (OPM)
administration of the Federal Employees Health Benefits (FEHB) Program.
I take seriously our responsibility to protect the privacy of Federal
employees, retirees, and their families who are enrolled in the
Program. I was, therefore, disappointed to find that the report failed
to articulate fully the results we have achieved in moving FEHB
carriers away from use of the Social Security number (SSN) as an
individual identifier for enrollees. Even though OPM staff provided a
complete history of the work we have done in this area, the body of the
GAO draft report barely addresses our accomplishments and the "Results
in Brief" section has no mention of them at all.
One year ago (September 5, 2003) I authorized instructing health
insurance carriers participating in the FEHB Program to discontinue the
use of SSNs on member identification cards. While some insurance
carriers had already discontinued use of (or never used) SSNs as
personal identifiers, most of the larger carriers were doing so at that
time. OPM told these carriers to replace membership cards with new ones
that do not display the SSN as soon as it was operationally and
financially practical to do so. We explained at the time to our
insurance carriers that "(t)he [SSN] can serve as a critical link in
identity theft cases, identity creation, and other crimes.... OPM is
joining the [Social Security Administration] in limiting the use and
display of the SSN."
Carrier response has been extremely gratifying. By the end of 2004, all
nationwide fee-for-service plans will be using unique identifiers on
their health insurance cards, as will many more HMOs. More than 93
percent of all FEHB Program subscribers will have unique identifiers on
their insurance cards by the end of this year. By the end of 2005, only
3.7 percent of FEHB Program subscribers will have their SSNs on their
health insurance identification cards. That means more than 3.8 million
subscribers will have a unique identifier rather than the SSN displayed
on their identification cards. We will continue to work with the
outlying insurance carriers until no FEHB Program subscriber
identification card displays an SSN.
We are proud of this important privacy initiative and would be pleased
to have GAO credit OPM's accomplishment more fully in your final
report. We also have comments or corrections on specific sections of
the draft report. Our comments are provided as an enclosure to this
letter.
Thank you for the opportunity to provide our comments to your draft
report.
Sincerely,
Signed by:
Kay Coles James:
Director:
Enclosure:
[End of section]
Appendix VIII: Comments from the Social Security Administration:
SOCIAL SECURITY:
The Commissioner:
September 24, 2004:
Ms. Barbara D. Bovbjerg:
Director, Education, Workforce, and Income Security Issues:
Room 5968
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Bovbjerg:
Thank you for the opportunity to review and comment on the draft report
"Social Security Numbers: Governments Could do More to Reduce Display
in Public Records and Identity Cards" (GAO-04-1047). We agree that as
the number of uses of an individual's Social Security number (SSN)
increases, so does the potential for misuse.
We appreciate your efforts to determine the extent, and reasons why, an
individual's SSN may be visible on government documents and records
that are made available to the public. We have worked in the past, and
will continue to work in the future, with other agencies - at the
Federal, State and local levels - to assist them in making their
processes less vulnerable to those who are intent on misusing SSNs.
Together we can take action to thwart those who would abuse the SSN and
other agencies' records to perpetrate identity crimes that burden
Americans and threaten the security of our nation.
With regard to the SSA-specific information, the report accurately
describes the guidance we provide to individuals regarding protecting
their Social Security cards from unnecessary exposure; i.e., do not
carry the card with you and keep the card in a safe place. It also
accurately cites the Privacy Act of 1974 as the rule that governs and
limits disclosure of. the SSN on Federal Executive Branch records.
If you have any questions, please contact Candace Skurnik, Director,
Audit Management and Liaison Staff at (410) 965-4636.
Sincerely,
Signed by:
Jo Anne B. Barnhart:
[End of section]
Appendix IX: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Alicia Puente Cackley (202) 512-7022:
Melinda F. Bowman (202) 512-3542:
Staff Acknowledgments:
The following team members contributed to all aspects of this report:
Dennis Gehley, Ron La Due Lake, Joel Marus, Nila Garces Osorio, and
John Trubey. In addition, Margaret Armen, Susan Bernstein, Carolyn
Boyce, Richard Burkard, Stefanie Bzdusek, Melissa Hinton, Catherine
Hurley, Chris Moriarity, and Caroline Sallee made contributions to this
report.
[End of section]
FOOTNOTES
[1] GAO, Social Security Numbers: Government Benefits from SSN Use but
Could Provide Better Safeguards, GAO-02-352 (Washington, D.C.: May 31,
2002).
[2] GAO-02-352.
[3] County recording officials typically maintain documents pertaining
to property ownership, including mortgages, deeds, and leases. Their
offices also may maintain wills, creditor filings, notices of liens,
military discharge papers, and marriage licenses. The responsibilities
of these officials varies by state and county and they may be referred
to by any number of titles including, clerk, recorder, register, or
auditor.
[4] While we received a completed survey from at least one program area
in each county, the response rates within each county varied from 1
program area in a county to all program areas. The response rates for
each program area were courts (79 percent), health departments (79
percent), law enforcement (80 percent), recording officials (88
percent), social services (79 percent), tax assessors (85 percent), and
voter registrars (86 percent).
[5] Population estimates are based on July 1, 2002, Census Bureau
estimates of the entire county population, adults and children. We
acknowledge that not all people in a county would be directly
identified on a public record but rather that there is the potential to
be identified on certain records.
[6] This provision is found at 5 U.S.C. 552a(note).
[7] For more information on the prior study and on the Privacy Act see
GAO-02-352.
[8] See GAO-02-352.
[9] The overall response rate for the state survey was 62 percent. In
37 states and D.C., we received responses from more than half of the
agencies surveyed. We received responses from about half or fewer of
the states in three functions: law enforcement, cosmetology licensing,
and notary public licensing. For the judiciary, human services, and
health services and vital statistics, three functions that we believe
are most likely to maintain records impacting large proportions of
residents, the response rates were 61 percent, 69 percent, and 60
percent, respectively.
[10] Population estimates are based on July 1, 2002, Census Bureau
estimates of the entire county population, adults and children.
[11] The county survey results were estimated based on a sample
allowing us to generalize to the population of U.S. counties. We are 95
percent confident that when sampling error is considered, the results
we obtained for the county survey are within +/-7 percentage points
unless otherwise indicated.
[12] The UCC addresses commercial transactions (including sales and
leasing of goods, transfer of funds, commercial paper, bank deposits
and collections, letters of credit, bulk transfers, investment
securities, and secured transactions). As used in this report, a UCC
filing--or financing statement--is a document stating that a person
(secured party) has a claim (security interest) in certain property
(collateral) financed for someone else (debtor). UCC recordings are
filed either at the state or local level, according to state law.
Typically, a person would not file a UCC financing statement unless
they are engaged in some form of commercial transaction that involves a
debtor and a secured party.
[13] The Privacy Act applies to records about individuals maintained by
agencies in the executive branch of the federal government. For a
fuller discussion of the Privacy Act see GAO-02-352.
[14] The act applies to records only if they are in a "system of
records," which means that they are retrieved by an individual's name,
SSN, or some other personal identifier.
[15] See Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978).
[16] 11 U.S.C. §107(a).
[17] The Privacy Act does not apply to Congress, the federal courts,
and other nonexecutive branch agencies (see §§ 551(1), 552(f)(1) and
552 (a)(1). However, it is the policy of the Administrative Office that
the intent of the Privacy Act be followed in the judicial branch.
[18] The Judicial Conference of the United States was created by
federal law and establishes policies for the judicial branch. The
Administrative Office of the United States Courts is the administrative
arm of the federal Judiciary charged with implementing Conference
policies.
[19] Survey respondents were asked to provide reasons for collecting or
using SSNs in public records. They were provided a list of responses
and asked to check all that apply for each record type. See appendix II
for a complete list of the survey questions and possible responses.
[20] The survey asked agencies to indicate actions taken in the last 2
years prior to administration of the survey in February/March, 2004.
[21] GAO-02-352.
[22] Developing CCJ/COSCA Guidelines for Public Access to Court
Records: A National Project to Assist State Courts, the National Center
for State Courts and the Justice Management Institute, (Oct. 18, 2002)
(www.courtaccess.org/modelpolicy/).
[23] Some of the major series of federal agency records that contain
SSNs stored in NARA records centers include alien case files, court
cases, employee medical folders, investigative files (including Offices
of Inspectors General), Medicare claims folders, official civilian
personnel folders, official military personnel folders, Social Security
Administration claims and litigation folders, tax returns, and folders
pertaining to deceased veterans and their dependents.
[24] The largest major series of name retrievable records in the
National Archives of the United States that contain SSNs include Navy
and Marine Corps muster rolls, 1971-76, and three Department of Defense
combat casualty databases, 1961-2002. SSNs also may be dispersed among
operations records such as Navy deck logs of nuclear ships and
Department of Justice case files.
[25] Report of the Judicial Conference Committee on Court
Administration and Case Management on Privacy and Public Access to
Electronic Case Files, http://www.privacy.uscourts.gov/Policy.htm.
[26] The Geneva Accord requires all military personnel and civilian
personnel accompanying the Armed Forces to have an identification card
showing the owner's serial number. DoD has employed the SSN as the
serial number. According to DoD, to remove this SSN from identification
cards would require a change to the Geneva Accord or a change to the
serial number that DoD currently employs. Of the 8 million DoD
identification cards that display SSNs, approximately 2.5 million meet
the requirements of the Geneva Accord.
[27] Social Security Administration, Your Social Security Number And
Card, Electronic Leaflet, SSA Publication No. 05-10002, July 2004.
[28] GAO-02-352.
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