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 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

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.. 

Highlights of GAO-05-59, a report to the 

Chairman, Subcommittee on Social 

Security, Committee on Ways and Means, 

House of Representatives 

November 2004

SOCIAL SECURITY NUMBERS 

Governments Could Do More to Reduce 

Display in Public Records and on Identity 

Cards 

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. 

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 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. 
Page i GAO-05-59 Social Security Numbers 

Letter 1

Results in Brief 3 

Background 5 

SSNs Are Widely Exposed in a Variety of Public Records Held by 

States, Local Jurisdictions, and Courts, but Less Exposed in 

Federal Records 8 

Identity Verification Is the Most Common Use of SSNs in Public 

Records 15 

Public Documents with SSNs Are Stored in a Multiplicity of 

Formats, but Hard Copy Is Still the Most Widely Available Form 

of Public Access 19 

Millions of Federal Health Insurance and Identity Cards Display the 

SSN 29 

Conclusions 31 

Recommendation 32 

Agency Comments and Our Evaluation 33 

Appendix I Objectives, Scope, and Methodology 35 

Appendix II State and Local Government Survey Questions 42 

Appendix III State Survey Response Rates by Function and State 47 

Appendix IV Extent of SSN Availability in State Public Records 50 

Appendix V Types of Public Records Held by Local Government 

Offices 52 

Appendix VI Comments from the Department of Defense 55 

Contents 
Page ii GAO-05-59 Social Security Numbers 

Appendix VII Comments from the Office of Personnel Management 56 

Appendix VIII Comments from the Social Security Administration 58 

Appendix IX GAO Contacts and Staff Acknowledgments 59 

GAO Contacts 59 

Staff Acknowledgments 59 

Tables 

Table 1: Availability of Public Records Containing SSNs by Number 

of States 9 

Table 2: Reasons Reported by State Agencies for Collecting or 

Using SSNs That Are Displayed in Public Records 16 

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 18 

Table 4: State Office Use of Multiple Storage Methods for Specific 

Types of Records Containing SSNs 21 

Table 5: Recent State Laws Restricting Public Disclosure of SSNs 

Cited by Survey Respondents 24 

Table 6: Out of Sample Respondents and Reasons for County 

Government Survey 39 

Table 7: Response Rates for State Functions Surveyed 47 

Table 8: State Response Rates 48 

Table 9: Record Type Forms Sent to Local Government Officials, 

by Functional Area 53 

Figures 

Figure 1: Types of Public Records Displaying SSNs Most Often 

Cited by State Offices 10 

Figure 2: Percent of Local Government Records with SSNs 

Available to the Public, by Function 11 

Figure 3: Percent of Counties in Which Specific Publicly Available 

Records Contain SSNs 13 
Page iii GAO-05-59 Social Security Numbers 

Figure 4: Percent of Local Government Records with SSNs, by 

Reason for Collecting or Using SSNs 17 

Figure 5: State Agency Practices for Storing Public Records That 

Display SSNs 20 

Figure 6: Methods of Access to State Public Records Containing 

SSNs 22 

Figure 7: Number of State Agencies Citing Each Change to SSN 

Access for at Least One Record Type 23 

Figure 8: Percent of Counties Giving Access to Public Records 

Displaying SSNs, by Method of Access 27 

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 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-59 Social Security Numbers 

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 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-59 Social Security Numbers 

records were making them available on their Web sites, but some were 

considering doing so or expanding the volume and type of such posting.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.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,3

 (5) social 

 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. 
Page 3 GAO-05-59 Social Security Numbers 

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.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. 

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.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 

 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. 

Results in Brief 
Page 4 GAO-05-59 Social Security Numbers 

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 
Page 5 GAO-05-59 Social Security Numbers 

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. 

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 

Background 
Page 6 GAO-05-59 Social Security Numbers 

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.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.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. 

 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.
Page 7 GAO-05-59 Social Security Numbers 

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.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. 

 8

See GAO-02-352. 
Page 8 GAO-05-59 Social Security Numbers 

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. 

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 rates9

). 

 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. 

SSNs Are Widely 

Exposed in a Variety 

of Public Records 

Held by States, Local 

Jurisdictions, and 

Courts, but Less 

Exposed in Federal 

Records 

Most States Display SSNs 

in at Least Some Public 

Records, but the Types of 

Records Vary 
Page 9 GAO-05-59 Social Security Numbers 

Table 1: Availability of Public Records Containing SSNs by Number of States 

In this many states 

This many types of public 

records contain SSNs

24 1 - 4

11 5 - 9

6 10 - 19

1 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. 

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. 
Page 10 GAO-05-59 Social Security Numbers 

Figure 1: Types of Public Records Displaying SSNs Most Often Cited by State 

Offices 

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. 

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.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 

 10Population estimates are based on July 1, 2002, Census Bureau estimates of the entire 

county population, adults and children. 

More Than 75 Percent of 

U.S. Counties Hold Some 

Public Records That 

Display SSNs 

0

2

4

6

8

10

12

14

16

18

20

Number of states

Source: GAO survey of state agencies.

19 19

16

15 15 15

11 11

Records of

criminal proceedings

Litigation and

civil case files

Death records

Traffic records

Records of

judgments

Uniform Commercial

Code filings

Divorce records

Business or

professional licenses
Page 11 GAO-05-59 Social Security Numbers 

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.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 

Note: The 95 percent confidence interval is within +/- 6 percent, except for recording officials, for 

which it is +/- 9 percent. 

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 

 11The 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. 

0

10

20

30

40

50

60

70

80

90

100

Percent

Source: GAO survey to local governments.

63

59

9 9 7 6

1

Courts

Recording

officials

Tax

assessor

Registrar

of voters

Law

enforcement

Health

department

Social

services
Page 12 GAO-05-59 Social Security Numbers 

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.12 Figure 3 shows the percent of counties 

in which specific types of records display SSNs to the public. 

 12The 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. 
Page 13 GAO-05-59 Social Security Numbers 

Figure 3: Percent of Counties in Which Specific Publicly Available Records Contain 

SSNs 

Note: The 95 percent confidence interval is within +/- 10 percent. 

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. 

0 10 20 30 40 50 60 70 80 90 100

Source: GAO survey of local governments.

54

50

43

43

40

35

38

39

31

28

28

28

24

13

19

22

9

10

Records of criminal proceedings

Records of property liens and other judgments

Litigation and civil case files

Traffic records

Mortgage and real property transfer records

Records of judgments

Child support records

Child custody records

Estate and inheritance records

Child paternity records

Military discharge records

UCC filings

Name change petitions

Property ownership records

Divorce records

Marriage licenses or applications

Records of criminal arrest warrants

Voter registration records

Percent of counties

Death records 18
Page 14 GAO-05-59 Social Security Numbers 

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. 

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.13 Specifically, SSNs in record systems—specific 

groups of records—held by federal executive agencies are generally not 

available to the public.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.15 Statutes also require records disclosure in some instances.16 

Social Security numbers are sometimes found in these records.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 

 13The 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. 

14The 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. 

15See Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978). 

1611 U.S.C. §107(a). 

17The 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. 

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 
Page 15 GAO-05-59 Social Security Numbers 

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.18

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.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. 

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. 

 18The 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. 

19Survey 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. 

Identity Verification Is 

the Most Common 

Use of SSNs in Public 

Records 

In State Public Records 

the SSN is Most Often 

Collected or Used for 

Identity Verification 
Page 16 GAO-05-59 Social Security Numbers 

Table 2: Reasons Reported by State Agencies for Collecting or Using SSNs That 

Are Displayed in Public Records 

Reasons for collecting or using SSN Number of state agencies

Identify verification 54

Matching with other records or data 40

Directed by state law or regulation 36

Data exchange or sharing 26

Directed by federal law or regulation 21

Used as file or record number 13

Benefit coordination or credit check 13

Other 30

No specific use 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. 

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 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. 

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 
Page 17 GAO-05-59 Social Security Numbers 

Figure 4: Percent of Local Government Records with SSNs, by Reason for 

Collecting or Using SSNs 

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. 

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 

0

10

20

30

40

50

60

70

80

90

100

Percent

Source: GAO survey of local governments.

4

47

18

7

2 2

31

7

File or

record number

Identity

verification

Benefit

coordination

Credit check

Directed by federal

law/regualation

Match with other

records/data

Data exchange

or sharing

Directed by state

law/regualation

Other

No specific use

26

20
Page 18 GAO-05-59 Social Security Numbers 

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 Function Survey response 

Records of criminal proceedings Court clerk It is provided to us; we don’t ask for it. 

Records of criminal proceedings Court clerk We don’t want them – they just put them on. 

Records of criminal proceedings Court clerk Other agencies provide – the court does not collect. 

Litigation and civil case files Court clerk Attorney places # on complaint & is not used by court in any way. 

Litigation and civil case files Court clerk SSNs are part of records file with us by parties to the action. 

Estate and inheritance records Court clerk We do not screen public records for SSNs & remove. If there, we leave 

them. 

Estate and inheritance records Court clerk We do not request the information, attorneys add it to some forms. 

Mortgage and real property transfer 

records 

Recorder Not required in Maine, but listed on some documents prepared out of state. 

Mortgage and real property transfer 

records 

Recorder SSNs are added by the mortgage companies. 

Mortgage and real property transfer 

records 

Recorder Documents are presented for recording with the # on them. We are not 

authorized to change. 

Mortgage and real property transfer 

records 

Recorder We do not use or collect. The lender chooses to put the SSN on the 

document. 

Records of property liens and other 

judgments 

Recorder We do not require SSNs for our purposes. 

Records of property liens and other 

judgments 

Court clerk Must record as presented. 

Records of property liens and other 

judgments 

Recorder We do not collect SSN. If they are on the document they are recorded. 

Records of property liens and other 

judgments 

Recorder Preparer of instrument does not want to remove the # from the instrument. 

Records of property liens and other 

judgments 

Court clerk Documents are received with SSN and we cannot alter or change any 

document. 

Military discharge records Recorder The SSN is on the document when it comes into the office. 

Military discharge records Recorder Already on record when presented. 

Military discharge records Recorder We do not use or collect SSNs – they are put on document by government. 

Child paternity records Court clerk Included in petition filed by attorney. 

Child paternity records Court clerk We have no control over the information people want to disclose in 

pleadings. 

Divorce records Court clerk Documents are submitted that way. 

Source: GAO survey of local governments. 
Page 19 GAO-05-59 Social Security Numbers 

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. 

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. 

Federal Executive and 

Judicial Branches Collect 

and Use SSNs for Purposes 

Required or Permitted by 

Law 

Public Documents 

with SSNs Are Stored 

in a Multiplicity of 

Formats, but Hard 

Copy Is Still the Most 

Widely Available 

Form of Public 

Access 
Page 20 GAO-05-59 Social Security Numbers 

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 

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. 

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. 

While State Public Records 

Containing SSNs Tend to 

be Stored Electronically, 

Public Access Is Usually 

Limited to Hard Copies 

0

10

20

30

40

50

60

Number of state agencies

Source: GAO survey of state agencies.

55

42

35

33

30

14

Electronic database or index

(MS Access, Oracle, etc.)

Microfiche/film

Electronic text file

(MS Word, Word Perfect, etc.)

Other electronic format

DVD, CD-ROM, disk,

diskette, or tape

Portable data file or other

 digital image (Adobe Acrobat,

 scanned image, etc.)
Page 21 GAO-05-59 Social Security Numbers 

Table 4: State Office Use of Multiple Storage Methods for Specific Types of Records Containing SSNs 

Number of state agencies 

Type of public record 

1 storage 

method

2 storage 

methods

3 storage 

methods

4 storage 

methods

5 or more 

storage

methods

Records of criminal proceedings 5 2 4 2 5

Litigation and civil case files 7 1 4 2 3

Traffic records 5 2 2 1 3

Records of judgments 4 1 3 0 3

Records of property liens and other 

judgments 3 1 3 2 1

UCC filings 5 2 5 2 1

Death records 3 5 6 0 1

Divorce records 4 1 4 1 2

Business or professional licenses 2 4 3 1 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. 

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. 
Page 22 GAO-05-59 Social Security Numbers 

Figure 6: Methods of Access to State Public Records Containing SSNs 

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. 

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 

0

10

20

30

40

50

60

70

80

90

Number of state agencies

Source: GAO survey of state agencies.

79

64

11

7

Mail request

Walk-in inspection

Internet access, fee and/or

registration required

Onsite use of electronic

database, fee and/or

registration required

Onsite use of electronic

registration required

database, no fee or

Internet, access, no fee or

registration required

11 10
Page 23 GAO-05-59 Social Security Numbers 

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 

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. 

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 

0

10

20

30

40

50

60

70

80

90

100

110

Number of state agencies

Source: GAO survey of state agencies.

109

68

36

Other

Restricted access

to records

Redaction (blackout) of

SSNs on copies

provided to the public

7

Use of partial SSNs or

some derivation of SSNs
Page 24 GAO-05-59 Social Security Numbers 

governments in the last 2 years.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. 

We previously reported that Washington and Minnesota had enacted 

comprehensive policies to restrict the display of SSNs.21 Minnesota’s law—

 20The survey asked agencies to indicate actions taken in the last 2 years prior to 

administration of the survey in February/March, 2004. 

21GAO-02-352. 
Page 25 GAO-05-59 Social Security Numbers 

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)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. 

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 

 22Developing 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/). 

Local Government 

Records with SSNs Are 

Most Often Stored on 

Microfiche or Microfilm, 

but Are also Posted to the 

Internet 
Page 26 GAO-05-59 Social Security Numbers 

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. 
Page 27 GAO-05-59 Social Security Numbers 

Figure 8: Percent of Counties Giving Access to Public Records Displaying SSNs, by 

Method of Access 

Note: The 95 percent confidence interval is within +/- 10 percent. 

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. 

0

10

20

30

40

50

60

70

80

90

100

Percent of counties

Source: GAO survey of local governments.

84

81

59

Mail request

22

Internet access

Onsite use of

 electronic database

Walk-in

inspection
Page 28 GAO-05-59 Social Security Numbers 

Federal agencies transfer paper records containing SSNs to records 

centers operated by the National Archives and Records Administration 

(NARA) for storage.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.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. 

 23Some 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. 

24The 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. 

Access to Many Federal 

Records Is Restricted, and 

Federal Courts Are 

Removing SSNs from Their 

Web Sites 
Page 29 GAO-05-59 Social Security Numbers 

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.”25

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. 

 25Report 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. 

Millions of Federal 

Health Insurance and 

Identity Cards Display 

the SSN 
Page 30 GAO-05-59 Social Security Numbers 

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.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.”27 In contrast, CMS 

 26The 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. 

27Social Security Administration, Your Social Security Number And Card, Electronic 

Leaflet, SSA Publication No. 05-10002, July 2004. 
Page 31 GAO-05-59 Social Security Numbers 

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. 

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 

Conclusions 
Page 32 GAO-05-59 Social Security Numbers 

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. 

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. 

Recommendation 
Page 33 GAO-05-59 Social Security Numbers 

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/. 

Agency Comments 

and Our Evaluation 
Page 34 GAO-05-59 Social Security Numbers 

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, 

Barbara D. Bovbjerg 

Director, Education, Workforce 

 and Income Security Issues 
Appendix I: Objectives, Scope, and 

Methodology 

Page 35 GAO-05-59 Social Security Numbers 

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. 

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 agencyspecific 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. 

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 

Appendix I: Objectives, Scope, and 

Methodology 

Federal Level 

Survey Development 
Appendix I: Objectives, Scope, and 

Methodology 

Page 36 GAO-05-59 Social Security Numbers 

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,1

 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. 

 1

GAO-02-352. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 37 GAO-05-59 Social Security Numbers 

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. 

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 

State Level 

County Level 
Appendix I: Objectives, Scope, and 

Methodology 

Page 38 GAO-05-59 Social Security Numbers 

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). 

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 

Local Government 

Sample Design 
Appendix I: Objectives, Scope, and 

Methodology 

Page 39 GAO-05-59 Social Security Numbers 

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 Number

Duplicate address 4

Office closed 2

Duplicate because 1 official performs 2 functions 3

Total out of sample 9

Source: GAO survey of local governments. 

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.
Appendix I: Objectives, Scope, and 

Methodology 

Page 40 GAO-05-59 Social Security Numbers 

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. 

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 

Estimation and 

Sampling Error 

Nonsampling Error 
Appendix I: Objectives, Scope, and 

Methodology 

Page 41 GAO-05-59 Social Security Numbers 

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. 
Appendix II: State and Local Government 

Survey Questions 

Page 42 GAO-05-59 Social Security Numbers 

Appendix II: State and Local Government 

Survey Questions 
Appendix II: State and Local Government 

Survey Questions 

Page 43 GAO-05-59 Social Security Numbers 
Appendix II: State and Local Government 

Survey Questions 

Page 44 GAO-05-59 Social Security Numbers 
Appendix II: State and Local Government 

Survey Questions 

Page 45 GAO-05-59 Social Security Numbers 
Appendix II: State and Local Government 

Survey Questions 

Page 46 GAO-05-59 Social Security Numbers 

The survey of state agencies asked the same questions with one addition: "How does 

your office transfer <record type> 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. 
Appendix III: State Survey Response Rates by 

Function and State 

Page 47 GAO-05-59 Social Security Numbers 

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 

Total number of states 

where function was 

surveyed

Response rate 

(percent)

Courts/judiciary 51 61

Law enforcement 44 52

Human services 51 69

Health services and vital statistics 47 60

Labor 50 76

Corrections 48 83

Public safety 30 57

Medical and health professions licensing 45 71

Cosmetology licensing 41 37

Notary public licensing 48 50

Securities profession licensing 45 62

Real estate licensing 42 64

Source: GAO survey of state agencies. 

Appendix III: State Survey Response Rates by 

Function and State 
Appendix III: State Survey Response Rates by 

Function and State 

Page 48 GAO-05-59 Social Security Numbers 

Table 8: State Response Rates 

State 

Number of agencies 

surveyed in state 

Response rate 

(percent)

Alabama 11 91

Alaska 11 45

Arizona 11 55

Arkansas 11 82

California 11 55

Colorado 12 50

Connecticut 10 60

Delaware 10 80

District of Columbia 10 60

Florida 9 89

Georgia 12 75

Hawaii 10 60

Idaho 11 82

Illinois 9 78

Indiana 10 60

Iowa 12 83

Kansas 11 64

Kentucky 11 36

Louisiana 11 45

Maine 12 50

Maryland 11 55

Massachusetts 11 55

Michigan 9 44

Minnesota 8 75

Mississippi 10 50

Missouri 12 58

Montana 11 36

Nebraska 9 67

Nevada 12 50

New Hampshire 12 25

New Jersey 9 67

New Mexico 12 58

New York 11 36

North Carolina 10 60
Appendix III: State Survey Response Rates by 

Function and State 

Page 49 GAO-05-59 Social Security Numbers 

State 

Number of agencies 

surveyed in state 

Response rate 

(percent)

North Dakota 11 55

Ohio 11 55

Oklahoma 11 64

Oregon 11 64

Pennsylvania 11 45

Rhode Island 8 50

South Carolina 10 60

South Dakota 11 91

Tennessee 10 60

Texas 12 83

Utah 11 82

Vermont 11 64

Virginia 12 83

Washington 10 70

West Virginia 11 91

Wisconsin 8 63

Wyoming 11 73

Source: GAO survey of state agencies. 
Appendix IV: Extent of SSN Availability in 

State Public Records 

Page 50 GAO-05-59 Social Security Numbers 

Number of states where 

Record type 

Records are available to 

the public and SSNs are 

shown

Records are available to the 

public, but SSN is not 

shown on public version 

Records are not 

available to the

public

Records of criminal proceedings 19 17 10

Litigation and civil case files 19 17 12

Jury lists 2 5 6

Estate and inheritance records 8 3 7

Traffic records 15 11 5

Records of judgments 15 12 12

Mortgage and real property transfer records 5 3 7

Records of property liens and other judgments 10 3 8

Property ownership records 3 5 7

Tax assessment records 3 4 15

Uniform Commercial Code (UCC) filings 15 3 0

Birth certificates 1 8 24

Adoption records 1 2 32

Child custody records 8 4 19

Child paternity records 6 6 29

Child support records 5 6 31

Divorce records 11 6 12

Death records 16 7 18

Marriage licenses or applications 3 9 13

Name change petitions 6 7 9

Concealed weapons applications 2 4 10

Hunting or fishing licenses 1 0 0

Military discharge records 2 8 19

Military induction records 1 1 6

Business or professional licenses 11 38 2

Public utility usage records 1 1 1

Social service case files or records 2 5 32

Vehicle or vessel registration records 1 2 6

Voter registration records 2 2 3

Notary commission records 5 7 3

Records of communicable diseases 1 2 15

Immunization records 1 1 20

Records of criminal arrest warrants 8 12 23

Appendix IV: Extent of SSN Availability in 

State Public Records 
Appendix IV: Extent of SSN Availability in 

State Public Records 

Page 51 GAO-05-59 Social Security Numbers 

Number of states where 

Record type 

Records are available to 

the public and SSNs are 

shown

Records are available to the 

public, but SSN is not 

shown on public version 

Records are not 

available to the

public

Prison records 6 20 18

Other records or files 16 20 12

Source: GAO survey of state agencies. 

Note: Based on responses from 338 of 542 state agencies surveyed. 
Appendix V: Types of Public Records Held by 

Local Government Offices 

Page 52 GAO-05-59 Social Security Numbers 

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. 

Appendix V: Types of Public Records Held by 

Local Government Offices 
Appendix V: Types of Public Records Held by 

Local Government Offices 

Page 53 GAO-05-59 Social Security Numbers 

Table 9: Record Type Forms Sent to Local Government Officials, by Functional Area 

Function Court clerks 

Health 

department 

Law 

enforcement 

Recording 

officials 

Social 

services Tax assessor 

Voter 

registrars 

Type of 

records 

Adoption 

records 

Birth certificates Concealed 

weapons 

applications 

Business or 

professional 

licenses 

Social service 

case files or 

records 

Tax 

assessment 

records 

Voter 

registration 

records 

 Child custody 

records 

Death records Prison records Hunting or 

fishing licenses 

 

 Child paternity 

records 

Immunization 

records 

Records of 

criminal arrest 

warrants 

Marriage 

licenses or 

applications 

 

 Child support 

records 

Records of 

communicable 

diseases 

 Military 

discharge 

records 

 

 Divorce records Military induction 

records 

 

 Estate and 

inheritance 

records 

 Mortgage and 

real property 

transfer records 

 

 Jury lists Notary 

commission 

records 

 

 Litigation and 

civil case files 

 Property 

ownership 

records 

 

 Name change 

petitions 

 Public utility 

usage records 

 

 Records of 

criminal 

proceedings 

 Records of 

property liens 

and other 

judgments 

 

 Records of 

judgments 

 Uniform 

Commercial 

Code (UCC) 

filings 

 

 Traffic records Vehicle or 

vessel 

registration 

records 

 

Source: GAO. 

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 
Appendix V: Types of Public Records Held by 

Local Government Offices 

Page 54 GAO-05-59 Social Security Numbers 

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. 
Appendix VI: Comments from the Department 

of Defense 

Page 55 GAO-05-59 Social Security Numbers 

Appendix VI: Comments from the 

Department of Defense 
Appendix VII: Comments from the Office of 

Personnel Management 

Page 56 GAO-05-59 Social Security Numbers 

Appendix VII: Comments from the Office of 

Personnel Management 
Appendix VII: Comments from the Office of 

Personnel Management 

Page 57 GAO-05-59 Social Security Numbers 
Appendix VIII: Comments from the Social 

Security Administration 

Page 58 GAO-05-59 Social Security Numbers 

Appendix VIII: Comments from the Social 

Security Administration 
Appendix IX: GAO Contacts and Staff 

Acknowledgments 

Page 59 GAO-05-59 Social Security Numbers 

Alicia Puente Cackley (202) 512-7022 

Melinda F. Bowman (202) 512-3542 

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. 

Appendix IX: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(130249) 
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