|Received:||8/31/2007 9:36:17 AM|
|Organization:||Enterprise Evaluation Services|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:I am retired police officer and I have been a private investigator for over 20 years. My primary duties are criminal defense appointments from the Los Angeles Superior Court and life insurance fraud investigations. Throughout the state of California there are hundreds of private investigators that are appointed by the courts to defend indigent defendants. The system is set up so that these investigators are not official employees and are culled from the private sector. Because of this, private investigators are not able to utilize the extensive net of official information. However, these investigators are required to provide the same services as the public defender investigators that do have access to official data. Routinely I am asked to locate and interview people, serve subpoenas, and prepare reports for the court. Although I am appointed by an official entity, the Superior Court, I do not have access to the same information that my counterparts in the public defender's office are able to access. Quite often the information I provide is a critical part of a criminal case or the information is used to prevent insurance fraud. The restricting of Social Security numbers for licensed private investigators will result in the proliferation of fraud. This restriction will also prevent the verification of witness names that will ultimately have a negative impact on the criminal justice process. Please reconsider the restriction and exempt licensed private investigators from any restrictive action concerning social security information.