TN 3 (09-05)

GN 03325.003 Verification of the Social Security Numbers (SSN) Without Consent

A. Policy - Verification Of SSNs

SSA employs the principles below in determining whether to verify SSNs for third parties.

NOTE: See GN 03325.025 for additional instructions concerning requests for SSN verification. Those instructions apply primarily to handling low volume requests for SSN verification.

1. SSN Verification Required by Federal Law

SSA will verify SSNs when a Federal law requires SSA to do so, regardless of the purpose stated in the law.

2. SSN Verification Without Consent is Allowed Under One of the Privacy Act’s Disclosure Exceptions (5 U.S.C. § 552a(b))

The Privacy Act contains 12 exceptions that allow SSA to release personal information, including SSN verifications, without consent (see GN 03301.020B.4. for a discussion of these exceptions). However, most of the SSN verifications SSA makes without consent are under the Privacy Act’s routine use exception (5 U.S.C. § 552a(b)(3)) (see GN 03325.003A.3.). SSA will make decisions on requests for SSN verification under the Privacy Act’s other disclosure exceptions, on a case-by-case basis. Under the routine use exception, SSA has already made a decision that disclosure may be made.

See GN 03325.003C. for examples of pre-approved requests for SSN verifications.

3. SSN Verifications Under the Privacy Act Routine Use Exception

The Privacy Act routine use disclosure exception (5 U.S.C. § 552a(b)(3)) allows SSA to verify SSNs for third parties without consent for purposes that are compatible with the purpose for which SSA assigns and uses the SSN. SSA has established routine uses applicable to the Master Files of Social Security Number (SSA) Holders and SSA Applications System that allow SSN verification under certain circumstances. This system of records and the routine uses can be reviewed at SSA’s Internet website, http://www.socialsecurity.gov/foia/ bluebook/600058.htm. See GN 03325.003C for pre-approved SSN verifications under the routine use and the other disclosure exceptions of the Privacy Act.

4. Disclosure for Law Enforcement Purposes

See GN 03312.000 for instructions that apply to requests for information for law enforcement purposes.

5. Federal Agencies Which Use the SSN as a Numerical Identifier in Recordkeeping Systems

Executive Order 9397 provides that whenever a Federal agency establishes a system of numerical identifiers, the agency should use the SSN. Upon request, SSA will verify SSNs for those Federal agencies which use the SSN as a numerical identifier in their recordkeeping systems consistent with the routine use exception in the Privacy Act.

B. Policy - Criteria For Verifying SSNs

1. Identifying Information Required

A request for SSN verification must include the SSN, name, and date of birth of the individual whose SSN a requester is seeking to verify.

A requester unable to provide the date of birth must provide one or more of the following identifying particulars:

  • place of birth,

  • mother’s maiden name, or

  • father’s name.

NOTE: If a request for SSN verification includes only the name and SSN, and SSA policy would otherwise allow the verification, you may verify the SSN only if you locate a single SSN record containing an exact match of that name and SSN with information in SSA files.

2. Justification for Disclosure

The requester must provide SSA with sufficient information to determine that the request meets SSA disclosure criteria.

C. Policy-Pre-Approved SSN Verifications Without Consent

The following are the most common SSN disclosures allowed under SSA disclosure policy. The listings are not intended to be all inclusive. Other disclosures may be authorized under a routine use listed in the notice of the Privacy Act system of records, Master Files of Social Security Number (SSN) Holders and SSN Applications System. This notice can be viewed on SSA’s webpage at http://www.socialsecurity.gov/foia/bluebook/600058.htm.

The chart below identifies pre-approved verifications of SSNs. The “REFERENCES” column identifies whether the particular disclosure is mandatory or discretionary. Unless otherwise noted in the chart, the component receiving a request may verify SSNs for the purpose stated.

NOTE: In most instances, the verifications are provided via electronic data exchanges under agreements between SSA and the agency receiving the SSN verifications. When SSA has an agreement with an agency to provide SSN verifications, it should be rare that the agency would need to request SSN verifications from a field office.

Volume manual requests for SSN verifications should be brought to the attention of the Office of Public Service and Operations Support, through the component Privacy Act Coordinator. 

AGENCY/THIRD PARTYPURPOSE OF VERIFICATIONREFERENCES

Department of Defense (DOD)

To assist in identifying those members of the Armed Forces and military enrollees who are aliens or noncitizen nationals that may qualify for expedited naturalization or citizenship processing in accordance with 8 U.S.C. § 1440 and Executive Order 13269. SSN verifications provided under a data exchange agreement.

GN 03313.005

Department of Education

For student loan applicants. SSN verifications provided under a data exchange agreement.

GN 03313.020.

Employers

To report FICA taxes and State or local Social Security taxes for employees under Section 218 of the Social Security Act, and

To correct earnings records.

GN 03316.080 and GN 03325.002.A.4.

NOTE: Encourage employers to submit requests for SSN verifications electronically. You may refer them to SSA’s Internal webpage http://www.ssa.gov/employer/evs2002.doc. for instructions on how they may submit requests electronically.

Federal, State, and local government agencies

To administer income-maintenance or health-maintenance programs. SSN verifications provided under data exchange agreements.

GN 03313.001A.4. and GN 03313.005.

Federal agencies using the SSN as a numerical identifier in their record- keeping systems

To verify the correctness of SSNs used as a numerical identifier in recordkeeping systems in accordance with Executive Order (EO) 9397.

GN 03313.001C.3.

Federal, State, or local law enforcement agencies

  • to protect the safety of SSA employees and customers, the security of the SSA workplace and the operation of SSA facilities;

  • to assist investigations or prosecutions with respect to activities that affect such safety and security or activities that disrupt the operation of SSA facilities.

  • to investigate or prosecute abuse of social security programs, including misuse of the SSN, or other income-maintenance or health-maintenance programs;

  • for criminal law enforcement purposes when the individual in question has been indicted or convicted of a violent crime; or

  • in a threat to national security or a life-threatening situation such as an act of terrorism, kidnapping or holding of hostages (see GN 03312.50B. for these requests).

GN 03312.000

Natural or Adoptive Parent or legal guardian of a person judicially determined to be legally incompetent)

When acting on behalf of the minor or incompetent person.

A parent or legal guardian requesting a minor’s SSN is deemed to be acting on the minor’s behalf when the request is for any of the following reasons:

  • to prepare a tax return (to claim the minor as a deduction),

  • to open a bank account,

  • to purchase stocks or bonds, or

  • for school identification.

Requests for other reasons are to be handled on a case-by-case basis.

GN 03340.015, GN 03340.025, GN 03340.030, and GN 03340.035.

Social security system of a foreign country that is a party to a totalization agreement

To carry out a purpose of an international social security agreement (i.e., totalization agreement) entered into between the United States and the foreign country under section 233 of the Social Security Act (Act) (42 U.S.C. § 433). SSN verifications provided under a data exchange agreement.

GN 03316.090

State and Territory Motor Vehicle Administration (MVA) officials (or agents or contractors on their behalf)

To verify the accuracy of information provided by the State agency with respect to applications for voter registration for those individuals who do not have a driver’s license number for whom the last four digits of the SSN are provided in accordance with section 205(r)(8) of the Act (42 U.S.C. § 405(r)(8)). Verifications of the last four digits of the SSN provided under a data exchange agreement.

GN 03314.145

State and Territory Motor Vehicle Administration (MVA) officials (or agents or contractors on their behalf) that collect the full SSN in accordance with Section 7 of the Privacy Act for voter registration purposes

To verify the accuracy of information provided by those State agencies that collected the full SSN of voter registrant applicants in accordance with the provisions of Section 7 of the Privacy Act, as allowed under section 205(r)(8) of the Act (42 U.S.C. § 405(r)(8)). SSN verifications provided under a data exchange agreement.

GN 03314.145

State MVAs

To issue driver’s licenses and MVA-issued identification cards in accordance with section 205(c)(2)(C)(i) of the Act (42 U.S.C. § 405(c)(2)(C)(i). SSN verifications provided under a data exchange agreement.

GN 03314.150

D. Procedure

See GN 03325.001D.


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GN 03325.003 - Verification of the Social Security Numbers (SSN) Without