Firms As Representatives Coming And Representative ID Number Too

Under the Privacy Act Social Security must publish notices of new systems of record keeping or alterations to existing systems of records. Here are some excerpts from a notice just published by Social Security -- and note the representative number, which sounds minor to some, but attorneys and others representing Social Security claimants have been very unhappy with using their Social Security numbers as a unique identifier:

We are altering the Appointed Representative File system of records specifically to implement an online suite of services for representatives. The online services will enable us to establish a framework of new business processes and systems enhancements and to provide comprehensive online services for representatives who wish to perform services on behalf of our claimants.

To ensure that we administer the appointed representative business process in a more efficient and effective manner, we propose to: ... (3) expand the category of records we maintain in the system to include the representative's date of birth, cell phone information, and representative identification number ...

Our long-standing policy is to recognize only persons as representatives. However, in the decades since we adopted that policy, the business practices of claimants' representatives have changed significantly. For example, many claimants prefer to hire a firm rather than a single person within a firm. Accordingly, to provide claimants better flexibility in pursuing matters before us, starting in 2010, we will recognize firms and other professional entities as representatives.