Operational Guidance | OG 25-2021 Pseudo Social Security Numbers (SSNs)
- Date: September 14, 2021
- Subject: Pseudo Social Security Numbers (SSNs)
- From: Chet Mottershead, Assistant Secretary for Workforce
Purpose:
To provide guidance that establishes the procedures regarding the use of Pseudo SSNs for performance reporting of participants enrolled in Workforce Innovation and Opportunity Act (WIOA) and Trade Adjustment Assistance (TAA) programs.
Background:
The U.S. Department of Labor Employment & Training Administration issued Training and Employment Guidance Letter (TEGL) 14-18, which provides guidance to states regarding the collection of participants’ SSNs when enrolling in employment and training services. Local NCWorks Career Center staff are required to “request” an individual’s SSN at program enrollment but cannot deny services if he or she chooses not to disclose it.
Local Area Workforce Development Boards (WDBs) must use the mechanism provided by the Division of Workforce Solutions (DWS) to create Pseudo SSNs. DWS has created a web page that will provide a Pseudo SSN generator to utilize in the provision of a random Pseudo SSN, when needed. The Pseudo SSN will be generated based on the WDB number and can be accessed at https://public.ncworks.gov/PSSN/. The Pseudo SSN Generator will verify that the SSN is not already in use before it is provided to the user.
TAA for Workers or Co-enrolled Dislocated Workers
Although TAA is one of the non-core programs that cannot deny service if a valid SSN is not provided, in order to receive Trade Readjustment Allowances (TRA), an individual must be TAA eligible and provide his or her actual SSN. (TEGL 14-18, page 18 and Attachment 10, page 5).
Unemployment Insurance Claims (UICs)
UICs will require an individual to use an actual SSN in order to file his or her weekly UIC.
Required SSN Notification
When requesting a WIOA eligible individual’s SSN, the individual must be informed, in writing, of the following, as applicable, to the particular program:
- Authority: The statute, regulation, Executive Order, or other authority under which the SSN is solicited. In general, the authority for collecting individuals’ SSNs is found in the WIOA and the regulations implementing WIOA.
- Purpose: The information may be used by additional government agencies that have access to the SSN if required by law.
- Opportunity and/or right to decline to provide SSNs: SSN disclosure must be voluntarily provided by the individual.
- Consequences of refusing or failing to disclose one’s SSN: Grantees cannot deny the individual access to services if the SSN is not provided. In such instances, the individual will be identified by an alternate unique identifier or Pseudo SSN. Grantees must follow appropriate practices in collecting, storing, handling, and transmitting Personally Identifiable Information (PII). DWS only sends unique identifier numbers to U.S. Department of Labor (USDOL), never an actual SSN. This unique identifier is separate from a Pseudo SSN.
For further guidance, reference TEGL No. 39-11, Guidance on the Handling and Protection of PII https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7872
Action:
Local Area WDBs and all contractor staff are to follow the guidelines and procedures outlined in this operational guidance in the provision of Pseudo SSNs to individuals who choose to not disclose his or her actual SSN. Staff may not deny employment and training services.
Effective Date:
Immediately
Expiration:
Indefinite
Contact:
Regional Analysts
Attachment:
Best Practices to Utilize When Requesting SSNs in the NCWorks Career Center