The use of the social insurance number (SIN) as a participant identification number in group insurance plansLinkedIn
There, in black and white
Bulletin NB Vol. 9 N. 2, April 2006
The protection of personal information is a growing concern for employers and employees. On January 1, 2001, the Personal Information Protection and Electronic Documents Act came into effect. The purpose of this Act is to better protect individuals’ privacy, including the security of their social insurance number (hereinafter called SIN). Several recommendations were made. For instance, the Commission d’accès à l’information du Québec (CAI) is against the use of the SIN as a participant identification number for group insurance plan.
Despite the CAI recommendation, several insurers continue to allow the use of the SIN as a participant identification number.
Last January, to assess the situation, we surveyed the main insurers on the use of the SIN as a participant identification number in their databases. The majority of these insurers agreed to participate in the survey, whose findings are summarized in the following table.
Findings regarding the change of the identification number to a number other than the SIN:
For long or short-term wage loss replacement insurance plans with taxable benefits, the insurer requires the SIN of disabled participants. For this reason, the insurer’s databases will generally include the SIN; however, they will not necessarily be used as identification numbers. The information will be available to the insurer, eliminating the need for certain steps for each new disability case.
If your insurer actually uses the SIN as a participant identification number and if this is a concern to you, we suggest you to discuss this with your insurer.
(1) Clients already insured with the insurer when the insurer decided to prohibit the use of the SIN as an identification number or to recommend the use of an identification number other than the SIN.
Please feel free to contact us for additional information.
630, René-Lévesque Blvd. West, 30th floor
Montreal, Quebec, H3B 1S6