|Received:||8/30/2007 11:19:47 PM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
|Attachments:||531096-00216.pdf Download Adobe Reader|
Comments:My firm has been in business since 1985. See attached CV for further background. Although we handle domestic cases, we mainly conduct investigations for Corporations. I am no way "demeaning" the status of domestic cases, but concerning your proposal, I want to focus on some real "critical situations". We perform background investigations (BI) for the transportation industry that hire permanent and part-time employees during their "busy" seasons. These companies transport volatile chemicals and dangerous products/goods, not just passengers, across the nation. We conducted BI's on 3 people who provided both name and SSN info for driver and airline positions. When we "ran" the names, we found nothing to indicate a potential problem, and they would have probably been hired. However, when we did an SSN# check, we found there were "AKA's" for each prospective applicant. When we "re-ran" these NEW names, we found major criminal and civil actions, and after conducting interviews of neighbors and acquaintances, determined these individuals had knowledge, ability, and motivation of carrying out potentially dangerous actions all across the nation. Without the ability to check the SSN#'s, we would have never found the additional names to "run" the other checks. We also handle cases for Microsoft, and preliminary info usually reveals suspects using various names. In one case, utilizing SSN's as subsequent "tools", we positively ID'd suspects and released the information to US Customs. Without the use of SSN info, we would have not been able to ID these suspects, and 200+ million dollars of illegal software, some with programs installed to track personal info and passwords, would have been released not only to individuals, but also Governmental entities (an order had been placed by a major LE agency from the suspects). Also, based upon the current man-power of almost every LE agency, many cases would not "get off the ground" and would either be ignored or require additional man-power to be diverted to "work the case up". We have submitted cases directly to the US Attorney's Office or DA's Offices for prosecution, thereby utilizing 0% of LE man-power. Many of the Government BI's being conducted, are by outside contract personnel (usually ex-employees), and with the current need for BI's both by Government entities and the private sector, the delays caused by limiting access to SSN info, would not only backlog the system, but increase the costs so dramatically, that companies would either limit their backgrounds or no longer conduct backgrounds at all. ID theft and crimes against the elderly are the fastest growing crimes in the US. We handle an average of 3-4 ID theft cases a month, and I understand that many legislators say that access to SSN info contributes to the problem. However, let me dispel some beliefs about ID theft. It is true that some companies who sell SSN info have been targeted and compromised regarding the release of data, but once an ID theft is committed, the consumer or company is instructed to report the theft to their local LE agency. Myth #1-Local LE Investigates ID Theft-Local agencies do not have the man power to investigate ID theft, and will generally handle about 1/6 of those reported. The local Southbay High Tech Crimes Task Force (CA) receives an average of 30 ID cases a month, but can only investigate 5-6 a month, due to man power. If there is any indication that the theft occurred through the mail, or had any "out of state" signs, the victim is told to contact the FBI or US Postal Inspector's. Myth #2-The FBI Investigates ID Theft-The FBI will not handle a case unless it meets a monetary "threshold", or there is a request for from another LE agency for assistance. I cannot disclose what these "thresholds" are, but they are very high. The only recourse an individual has is to hire a "licensed" PI to investigate the matter, and without access to SSN info there would be no way to track or ID these criminals.