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Normandin Beaudry

The use of the social insurance number (SIN) as a participant identification number in group insurance plans

LinkedIn

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.

Key findings:

  •  The majority of insurers continue to use the SIN as an identification number for existing clients(1);
  • For new clients(2), insurers do not recommend or prohibit the use of the SIN as an identification number.

Findings regarding the change of the identification number to a number other than the SIN:

  • Some insurers recommend changing numbers while others will proceed with the change at the client’s request only;
  • Only two of the eight insurers who participated in the survey charge fees for changing identification numbers and a third one may charge some fees for certain groups with specific features.

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.

Summary of survey findings

InsurerUse of SIN as
identification number
(existing clients (1))
Policy on the use of
SIN for new clients(2)
Change to an identification number
other than SIN

Insurer A Yes Not recommended (3) Upon request - charges apply
Insurer B Yes Not recommended (3) Recommended change - no charge
Insurer C Yes Not permitted Recommended change - no charge
Insurer D Yes Not permitted Change initiated in 2005 for all groups
- no charge
Insurer E Not recommended for
several years
Not permitted Recommended change - no charge
Insurer F Never permitted Not permitted Not applicable
Insurer G Yes Not recommended (3) Upon request - charges apply
Insurer H Yes Not permitted Upon request - charges apply (4)

(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.
(2) Clients whose insurance contract with the insurer took effect after 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.
(3) The insurer recommends the use of an identification number other than the SIN but does not prohibit the use of the SIN as an identification number.
(4) Fees may be charged for specific groups only. 

 

Please feel free to contact us for additional information.

514.285.1122
 
630, René-Lévesque Blvd. West, 30th floor
Montreal, Quebec, H3B 1S6