| Comment Number: | 531096-00180 |
| Received: | 8/28/2007 2:42:45 PM |
| Organization: | Association of Christian Investigators-Oklahoma Chapter |
| Commenter: | Nicolin Decker |
| State: | OK |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
To Whom It May Concern: What businesses and organizations collect and use the SSN? All active Private Investigators, Insurance Companies, Third Party Administrators, and Attornies across the United States utilize SSN. For what specific purposes are they used? We use SSN: (1) to locate person/s who have gone into hiding because they are or have committed fraud or some other crime (2) to conduct a background search on a person/s so that we can help keep society safe and prevent further crimes from happening (3) it is used as an authenticator for locates and background searches, whereas other information cannot be relied upon. What is the life cycle (collection, use, transfer, storage and disposal) of the SSN within the businesses and organizations that use it? The collection of SSN comes strictly in a lawful and professional manner and the use of such SSN is used only as long as the case is active. We do not transfer a person/s SSN out of the locked safekeeping of any Private Investigator's Agency to any unauthorized person/s for any reason. Storage of SSN is kept only as need typically until a case is permanently closed. Disposal of SSN are shredded and disposed of at a safe disposal agency. Are governmental mandates driving the private sector’s use of the SSN? The current and past laws that restrict Private Investigators from certain information forces Investigators to rely more and more upon SSN. Are there alternatives to these uses of the SSN? Currently there is no substitute for SSN. What has been the impact of state laws restricting the use of the SSN on the private sector’s use of the SSN? It has caused more crime i.e. fraud, stealing, and other criminal activity of this type to increase. It has also made our jobs significantly more difficult to the point where we cannot even work some cases due to the fact essential information is restricted from us. We understand the need for increased security for the people of the United States more than anybody else because our industry gives us a unique perspective. We request that Private Investigator are not restricted from utilizing SSN in our cases. We perform investigations all across the United States that law enforcement agencies cannot and will not take because it is not in their jurisdiction, not in their budget, or they deem it not important enough. Many times we perform investigations that turn into federal, state, or local cases because we have built up enough evidence for that law enforcement agency to act on. If Private Investigators are restricted from using SSN then we will not be able to perform certain cases like workers' compensation case because for the most part we rely totally upon what information comes from the SSN. Also it could put many of us out of our jobs. 99.9 % of Private Investigators are hardworking, honest, dedicated people that provide an invaluable service across the United States. Thank you for your time, it is much appreciated. Sincerely, Nicolin Decker, President Association of Christian Investigators Oklahoma Chapter P.O. Box 1286 Norman, Oklahoma 73070 www.aci_ok.com (405) 556-1196