As the employer you must ensure that your employees are correctly identified. Requesting pieces of identification upon hiring is usually the first step to verify your potential employee is who they say they are.
Relationship Between Legal Name and SIN Record
It is a best practice to record the employee’s legal name for payroll purposes. Many people prefer to be addressed by a nickname, abbreviated name, or another name and will usually use this as they fill out their onboarding package. It is also in your employee’s best interest that their SIN record reflects their current legal name. Current legislation states that if a legal name change has taken place due to marriage or other reasons, the SIN holder must apply to update their SIN record under their new name within 60 days. If the legal name, and the name used on the SIN record of your employee doesn’t match, there may be processing delays with respect to employment benefits if their employment is terminated.
Can SIN’s be Used to Identify Employees?
An employee’s SIN should not be used as an employee number to identify them. As an employer, you are strongly discouraged from using employee SIN’s for this purpose because of the serious problems that could arise from having the employee's personal information at risk. A best practice is to use another system to identify your employees. It is recommended that you use a basic numbering system or an alphanumeric system to identify your employees, protecting their privacy and maintaining the integrity of all employee SIN’s.
Verifying the SIN of an Employee
If you are hiring a new employee and suspect they may not be who they claim to be, there is a resource available to you. You as an employer, can contact Service Canada at 1-800-206-7218 and select option “3” to verify the SIN of any current or past employees. When you call, you will be asked to provide your business number as provided by the CRA, identification about your company and must verify the SIN holder’s information. As a note, only you can verify an employee's SIN from the Social Insurance Registration Office. If you are using a payroll service provider, THEY cannot verify SIN’s with the Office. It is also an important step to provide your payroll service provider with correct/verified employees SIN’s because in the event of an employee discrepancy, you may be responsible for any unpaid deductions or taxes.
When to Collect SIN’s
As an employer, you are required by law to request the SIN of each new employee within their first 4 days of employment. You must also ensure employees are correctly identified by requesting identification when filling out new hire information forms. It is your duty to ensure your employees have a SIN on file. This is the number used to administer government benefits under the Income Tax Act, the Canada Pension Plan and the Employment Insurance Act.
Protecting Employee SIN’s
You are obligated to protect the SIN’s of your employees and their personal information from theft and misuse. To enforce this, only authorized people should be given access to this information. All employee personal information must be stored and disposed of properly and securely. According to the Employment Insurance Act , the Canada Pension Plan Act and the Income Tax Act , if you have employees that you withhold or deduct CPP contributions, EI premiums and taxes, you are required to keep their SIN and personal records for at least six years from the end of the year your employee was terminated.
How to Distinguish a Temporary SIN
A temporary SIN will begin with the number “9” and also have a period of validity. You will encounter this if you have a foreign worker that is authorized to work in Canada and has been granted citizenship by Immigration Canada (CIC). The temporary SIN is also issued to people who are legally entitled to work in Canada but may not be Canadian citizens or permanent residents, such as temporary/seasonal workers.
Service Canada's Commitment to Employers
As you continue to bring new employees on board, Service Canada will continue to be your go to resource for SIN concerns. For more information on SIN’s, and to view other ways Service Canada is available to help with regards to SIN’s, please visit https://www.canada.ca/en/employment-social-development/services/sin/reports/code-of-practice/section-3.html.
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