There are still too many stories and cases about people stealing and misusing SSNs.  While those instances are always terrible, there are even worse consequences when it’s the SSN of a young child or teenager.  In those instances, the young child or teenager might not know for years that his identity has been stolen using this very powerful source of personal identity.

The good news is that there could be some additional relief soon specifically involving those cases where the SSN is of a child 13 years and younger.  The Social Security Administration (SSA) issued a request in February for comments on a proposed policy change to assign new SSNs specifically for children age 13 and younger (February 11, 2012, Fed. Reg., Docket No. SSA 2012-0042; “Assigning New Social Security Numbers (SSN) for Children Age 13 and Under”).

Under the proposal, SSA would assign new SSNs to children in that age category under any one of the following 3 situations:

  1. The child’s Social Security card has been stolen in transit;
  2. The child’s SSN has been incorrectly disclosed via the SSA’s publicly available “Death Master File”; and
  3. The child’s SSN has been misused by a 3rd party.

In its request for comments, SSA asked if the age cut-off is appropriate; if the 3 scenarios are appropriate; and if there are other scenarios or circumstances that would warrant assigning a new SSN to a child 13 years and younger.

Staff from the Federal Trade Commission (FTC) submitted comments on April 12th supporting the SSA’s policy proposal.  They recommended that the age group be expanded to children 17 years old and younger.  Their recommendation is based on the fact that many younger children (e.g., 13 and younger) might not know for several years that they’ve been identity theft victims. They might not learn about their victimization until they are first applying for credit or a loan or for some other transaction for which their credit status and/or SSN is needed (see, http://www.ftc.gov; “FTC Staff Comment Supports Proposed Social Security Administration Policy Change to Help Protect Children from Identity Theft”).

The FTC staff made other recommendations that would also help enhance what is already a very sound and, sadly, much needed policy proposal.  The SSA is taking a needed step to help protect children who are, or have been, victims of identity theft.