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• SSN Trace Functionality, Randomization and Validation

  SSN Address Trace Results

  The SSN Trace is primarily used as a record locator device and therefore no employment decisions should be made on the results of this check. Consultation with qualified legal counsel is recommended for all employment law matters.  As such, Info Cubic will not apply a result disposition (i.e. Clear or Review) to the SSN Address Trace.  The search will be displayed as “Complete” and will have one of the following results:

  • Return all name and address history results so long as the last name input is found at least once on the corresponding SSN Address Trace records.
  • A notation in the body of the search result that says, “No name or address records found. Either the supplied Social Security Number (SSN) does not match the provided name or there is no name and address history associated with the supplied SSN.”  In this scenario, either the client or applicant made a typo in error or provided an incorrect SSN purposefully.  It is also possible there is no name or address history associated with the SSN.  That could be the case when someone is very young and has not applied for credit, utilities, housing, etc. 

  SSN Randomization

  Occasionally you may see “unable to validate SSN” on the SSN Trace results in The Cube under the state and year issued. Whenever this result comes back, it’s due to SSN Randomization.

  The Social Security Administration (SSA) changed the way Social Security Numbers (SSNs) are issued on June 25, 2011. This change is referred to as "randomization." The SSA developed this new method to help protect the integrity of the SSN. SSN Randomization will also extend the longevity of the nine-digit SSN nationwide.

  The SSA eliminated the geographical significance of the first three digits of the SSN, referred to as the area number, by no longer allocating the area numbers for assignment to individuals in specific states. (Resource: https://www.ssa.gov/employer/randomization.html). 

  Essentially what happened was the SSA recognized it would eventually run out of numbers to assign using the geographic significance method and so it transitioned to the Randomization process. Thus, anyone obtaining a new SSN will not be tied to a particular geography given the randomization. This process does not impact any SSNs issued before June 25, 2011. Additional FAQs supplied by the SSA may be found here: https://www.ssa.gov/employer/randomizationfaqs.html.  

  SSN Validation

  The SSN Trace is not intended to officially verify or validate an individual’s SSN. Info Cubic also offers a Consent Based Social Security Number Verification (CBSV) product that verifies that the SSN holder’s name, date of birth and SSN directly match the official governmental source records of the SSA Master File and Death Index. The CBSV is distinct from the SSN Trace product offering.

• Screening Minors in the United States

  It is legally permissible to conduct background checks on individuals under the age of 18; however, please be aware that there may not be a lot of information returned. Here are some highlights as to different searches and consent forms.

  • Education: Odds are the individual is still in high school, not currently enrolled or working towards a GED. There may not be education experience to verify.
  • Employment: Likely a minor candidate hasn’t had any prior employment experience that is likely relevant/necessary for the job being filled.
  • MVR: There is likely minimal MVR history, although this is one search that may make the most sense if the minor will be driving such as if he/she is applying to deliver food.
  • Criminal: Juvenile records are not reportable. There may be an instance where a minor has committed a crime and been tried as an adult which would be reportable. However, if that is the case, it’s likely for a serious offense that would require a period of incarceration which probably means the minor is not out applying for a job. However, given the emphasis on workplace safety and protection from negligent hiring, a criminal search may still be a good idea.
  • References: This could be useful depending on the position.

  Credit Reports

  As for credit history, we will not process a credit report on individuals under the age of 18. Typically individuals under 18 only have credit history if a parent/guardian lists them as a joint account holder or authorized user. Another way an individual under 18 would have a credit report is due to identity theft. There have been instances where individuals will use the minor’s information to open accounts, run up debts, etc. without the minor or the parent/guardian ever knowing since minors do not really ever apply for credit (usually you have to be 18+ to apply for loans, open a credit card, etc.). The credit bureaus differ slightly on process, but they will accommodate security freeze requests from parents to help prevent this matter from happening. However, if no file is created in the first place for the minor the credit bureaus typically do not create a file unless required to do so under state law. The Consumer Financial Protection Bureau has a helpful article on the topic: https://www.consumerfinance.gov/askcfpb/1271/should-i-request-credit-reports-my-children.html.

  Consent

  Our recommendation is to have the minor’s parent or guardian sign the disclosure and authorization form as minors are not typically thought of as capable of providing consent.

• International Consent Forms and Guidance

  The disclosure and authorization form you use for U.S. background screening purposes is designed to meet the requirements under the Fair Credit Reporting Act (and any other applicable state laws). It should not be used for screening outside of the United States.

  For international screening purposes, each country is different with unique laws and regulations, particularly with regard to data privacy. There may also be specific consent language requirements depending on the searches ordered.

  A common theme among several data privacy laws is that the data subject (i.e., the candidate) must be informed as to who is receiving, collecting and/or processing the personal data and why. Additionally, in many countries within the European Union, consent must be provided that is specific, freely given and informed. Many experts believe that consent as it relates to employment can never truly be “freely given” which may mean a candidate could refuse consent to a background check without being adversely impacted.

  We do have a sample international consent form that can help start you in the right direction. Given the complexities involved with international screening, particularly with regard to consent issues, we always recommend consultation with a qualified legal expert to ensure your background screening program remains in compliance with all applicable laws and regulations.