|Received:||8/28/2007 1:51:54 PM|
|Organization:||Mark W Stephens & Associates|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:As a 24 year licensed Texas Peace Officer, and a licensed private investigator, I can tell you that the use of SSN's in my proffession, both on the law enforcement side and the private investigations side, is an integral part of the investigations that we conduct. Using a suspect's SSN as a means to identify that person is extremely important in the investigations that we conduct and the loss of the use of SSN's as an identifier would be detrimental to investigations. Not only would we be unable to properly identify potential criminal suspects, we would also be unable to verify an individual's true identity. For purposes of background investigations, there would be no competent way for us to check an individual for pre-employment and determine if the person was a legal resident without being able to check their SSN. I agree with limiting access to SSN's to the general public, but there is no need to remove access to SSN's from licensed investigators who are required to be insured and rely on SSN's to conduct legally authorized investigations. Moreover, removing the access to SSN's to such investigators could cause serious liability issues because of false or mistaken identification of suspects or potential suspects.