|Received:||8/29/2007 8:50:53 AM|
|Organization:||TERRY VAN WHITNEY LEGAL SERVICES INC.|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:A broad, indiscriminate ban on the display or sale of Social Security numbers would result in severe unintended consequences for law enforcement, private and public security, and the judicial system. Private investigators and security professionals use databases for a number of vital purposes, including locating witnesses, assisting identity theft victims, finding deadbeat parents and fighting fraud. If we are unable to access the identifying information in databases, we will not be able to perform these functions. I am attaching a three-page document that outlines vital investigative services for which continued access is necessary. We do urge Congress to permit regulated, licensed private investigators to continue to have access to Social Security numbers and other identifying information. As state entities that regulate private investigators, we know that they serve a vital role in our judicial system. Investigators help locate witnesses, find heirs, solve identity theft and other cases of fraud, and reunite children with their parents. If they are prevented from obtaining information they need to help locate individuals, then courts may be deprived of some evidence, and some criminals may be able to escape justice.” Most of the recent breaches involved computer hacking, insider theft, or lost shipments of information. Limiting access to information that is critical to the judicial system would not have prevented those losses. Thefts like the one which occurred at ChoicePoint will be deterred by new credentialing policies which have already been adopted.