|Received:||8/6/2007 10:19:30 AM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:By law, SSN should be used ONLY for Federal purposes in taxpayer identification. The number of organizations now using this information for unrelated purposes is staggering and infuriating. New Jersey DMV requires SSN for all applications; this could easily be replaced by a system which tracks existing drivers licence records across states, although it might be useful/necessary for new applications. One must explicitly "opt out" of having this information on the driver's license in order to prevent having a copy of your SSN in your wallet where it could be easily stolen. I have had a number of medical professionals argue that I needed to provide my SSN, rather than a separate medical identifier that my insurance company has allowed. In addition, credit bureaus should have a different means for identifying credit records. Their use of the SSN makes it impossible to apply for credit or even sign an apartment lease without releasing your SSN to third parties, who need it for a credit check, but who (even with no ill intent) may not be protecting the records adequately. At this time, it appears that educational institutions are finally moving away from the SSN as a student ID; several have contacted me to offer a "replacement" ID number that is distinctive. This is among the most critical places for such a correction to occur, as there is NO demonstrable need for the SSN in this context, and students are often too young to be aware of their right to refuse the use of the SSN or of the identity theft risks involved.