|Received:||8/28/2007 8:00:05 AM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Re: "SSNs in the Private Sector - Project # P075414 Dear Sir: I retired from the Lima Police Department, and have been a licensed private investigator in the State of Ohio for 9 years. Acquiring SSN's is very important for our work. We work closely with law enforcement and forward criminal activity information to them on a frequent basis. That type of activity includes drug sales & usage, fraud, and other criminal matters. We also locate people for attorneys that have pending litigation. The people located for the attorneys include witnesses, and often times their own clients that have relocated several times since the case began. So, the people that we locate are important to court cases. We also work closely with the Adult Parole & Probation department and interview sex offenders, and subsequently conduct truth verification testing. We conduct investigations regarding Worker's Compensation Fraud, and often turn video over to the state agency for criminal prosecution. In each of the instances, plus many other circumstances, obtaining the person's social security number is a vital part of our investigation. It is a method that separates all the John Smith's and other common names. If the social security number is taken away from us, not only will we suffer, but so will many other people and agencies that we assist. In most cases it will be increasingly difficult to locate and positively identify someone, which lessens the ability to use information in Court or for criminal prosecution. I am very much in favor of privacy issues; however, they should be applied to the general public, not to licensed investigators. Make the distinction that holding a license puts a professional investigator, with a permissible purpose, above the general public and should continue to give licensed investigators the ability to acquire social security numbers, just like law enforcement. Thank you for your consideration.