2007 February Status Report of the Auditor General of Canada

Appropriate use of the Social Insurance Number

6.28 The Treasury Board Secretariat should

• meet its commitment to update the policy framework governing the use of the SIN in the federal government by 31 March 2008, and
• ensure that the policy instruments governing the use of the SIN in the federal government close the gaps identified in its 2003 review.
  (6.14–6.27)

The Treasury Board Secretariat is committed to ensuring that the personal information of Canadians is protected in accordance with the provisions of the Privacy Act and the requirements of the Policy on Privacy and Data Protection, which governs use of the Social Insurance Number (SIN) and data matching by federal government institutions. As the Auditor General has noted, the Secretariat has already completed significant work on developing the proposed policy changes governing the use of the SIN and data matching. The Secretariat has completed a review of SIN and data matching practices across the federal government and prepared a comprehensive report in 2003. Extensive consultations have been undertaken with other federal institutions through a Secretariat-led Interdepartmental Committee and, as well, the views of the Office of the Privacy Commissioner have been sought on the proposed revisions.

The Secretariat will ensure that the Treasury Board policy requirements governing use of the SIN in the federal government are updated and clarified by 31 March 2008, to close the gaps identified in the 2003 Secretariat review.

The Social Insurance Register

6.75 When using the Register to validate identity, Human Resources and Social Development Canada and Service Canada should ensure

• key Register information is up to date,
• key Register information is used, and
• their follow-up actions are commensurate with risk.
  (6.70–6.74)

The Department recognizes the importance of maintaining the integrity of key Register information and supports establishing efficient, effective, and consistent SIN validation processes. Since 2002 the Department has undertaken a number of initiatives to strengthen the integrity of key Register information, including introducing an expiry date on SINs issued to temporary workers to coincide with their authorized stay in Canada, and implementing agreements with Ontario and British Columbia to directly receive and validate birth and death information (representing 54 percent of the population).

To further ensure that key Register information is up to date, Service Canada is continuing its negotiations with other provinces and territories to implement similar agreements to receive and validate birth and death information. The Department is also continuing to ensure that due diligence is met with regards to the treatment of dormant flags.

Service Canada will undertake a study to confirm the use, usefulness, and relevance of the existing information, including risk flags, for programs that use the Register to validate identity. Options will be assessed to address identified weaknesses and implement necessary corrective measures in SIN-related program areas.

Moreover, the Department will continue to conduct investigations and follow-up commensurate with identified risk for programs under its responsibility.

6.78 Human Resources and Social Development Canada and Service Canada should

• set goals for the accuracy, completeness, and reliability of the data in the Social Insurance Register; and
• implement a comprehensive quality management program to systematically measure, maintain, and report on the quality of the data in the Register.
  (6.50–6.77)

The Department agrees that establishing goals is important. At the same time, performance targets must be based on sound analysis. Therefore, prior to establishing goals, Service Canada undertook a number of studies on the accuracy of key fields in the Register, the use of vital events information, and the preparation of methodologies to estimate benchmark levels of Register error.

Service Canada will complete its work currently under way on benchmark levels to define key performance indicators for the ongoing measurement of Register completeness, accuracy, and reliability. Based on these results, Service Canada will establish goals for Register data and develop a plan to measure and report on performance in the 2007–08 fiscal year.

6.85 Human Resources and Social Development Canada should ensure that its next reports to Parliament on the management of the Social Insurance Number and improvements to the Register include

• clear and concrete performance expectations,
• time frames for achieving these expectations,
• key results reported against these expectations, and
• explanations for gaps and shortcomings in the results achieved.
  (6.79–6.84)

The Department is fully committed to continuing improvement in the management of the Register and the SIN and will address the Auditor General's recommendations in future reports to Parliament, such as the Departmental Report on Plans and Priorities and the Departmental Performance Report, once goals have been established.

Investigations related to the Social Insurance Number

6.93 Human Resources and Social Development Canada and Service Canada should implement a means to evaluate and monitor the causes and results of SIN investigations and use this information to ensure investigation efforts concentrate on high-risk areas.
(6.86–6.92)

The Department is developing an enterprise-wide approach to risk management, and the SIN Application Review Program (SARP) is an integral part of this risk approach. The SARP is a front-end process, in which staff involved in taking SIN applications are required to assess the information presented and the client's demeanour. This is used to determine whether additional information is needed or whether the application should be referred to an investigator.

The Department plans to analyze and monitor the causes and results of SIN investigations, including the key factors related to the SARP, such as documentation used for the SIN application, and use these to target high-risk SIN investigations in the future.

6.97 Human Resources and Social Development Canada and Service Canada should ensure that investigators have access to current training and tools for identifying fraudulent documents and investigating SIN-related fraud.
(6.94–6.96)

The Department has developed training and tools to assist investigators in identifying fraudulent documents and investigating SIN-related fraud. This material will be regularly updated to ensure it remains complete, accurate, and relevant in conducting investigations on SIN-related fraud.