|Received:||8/31/2007 11:03:11 PM|
|Organization:||CIPI Certified Investigative Professionals Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:On behalf of CIPI, a professional private investigator’s organization, I urge the FTC Commission to give special weight, emphasis added, on the negative impact restricting/prohibiting a PI’s use of the SSN for legitimate purposes. PIs are not the problem; criminals are the problem! Criminals are abusing the system and exploiting opportunities to get rich off the backs of unsuspecting victims, Joe and Joan Q Public, through unscrupulous means such as identity theft and fraud. However, prohibiting/restricting a PI’s use and reliance on SSN driven databases will have an [unintended] adverse impact on the very people you are trying to protect! Ironic as it may seem, congress’s proposal to make SSNs unusable for any purpose in the private sector, will have a devastating effect on the private sector’s ability to accurately and correctly identify the very persons that should be held to answer for their illegal and malicious actions! For example, employers deciding to hire, witnesses needed to be located for trial, the need to locate deadbeats/judgment debtors for collection, reuniting missing persons with their loved ones, locating unclaimed property for families and the elderly, identify insurance fraudsters and fraud ring trends, locating deadbeat parents, etc. Surely, any reasonable and logical person can see that taking away a necessary tool from the private sector will only undermine the accuracy and effectiveness of the private sector’s right to perform due diligence. We are certain that any restrictions or prohibitions specifically targeting PIs from using SSNs in their investigations, will do more harm/damage to the same people you are trying to protect from privacy violations. The prohibition will not stop or stem identity theft, but restricting a PI’s use of the SSN tool will surely make it easier for charlatans, deadbeats, sham artists, fraudsters, and criminals to commit their crimes on innocent victims and go undetected. You have to recognize the significance PIs, law enforcement, and countless other professions rely upon the SSN as the “primary identifier” for Joe Q Public! “Names and dates of birth” are no longer “unique” to one person! Social Security Numbers, however, are unique to one person. In the case of financial malfeasance, identity theft, fraud, unjust enrichment, payroll fraud, taxpayer fraud, loan fraud, to name a few, PIs rely on the traceable tracks that SSN driven databases leave by the culprits. PIs do not have the luxury of running fingerprints or DNA samples on suspected fraudsters, etc. We have to piece together the tracks of the perpetrators through various means, many of which are social security number driven searches. Names are so common these days and so many criminals perpetrating crimes use aliases names etc. that PIs have to have access to databases where we can use SSNs, [the unique primary identifier] to have even a remote chance to collar the bad guy. Unfortunately, anyone with a creative mind and an IQ of 50 can randomly align nine digits in an acceptable Social Security number format and presto they have a “new Social Security Number!” The good news: The digit string in an SSN makes for a very effective logic search query in most, if not all, database search engines. With the Social Security Number of a victim or a perpetrator our changes of tracking down the culprit increases exponentially! On the other hand, if the FTC prohibits our use and access to social security number driven searchable databases, criminals will have the advantage not PIs or law enforcement. Private Investigators use the Social Security Number in most, if not all, their investigations in some way to aid us in accomplishing the requested tasks. Whether we like it or not, the SSN is the private sector’s most accurate means to identify legitimate citizens from the impostors committing the many types of crimes against the innocent. The necessity of our use of the SSN has reached a critical mass. The SSN has become the most unique non-bio identifier of all time. The SSN’s use as an identifier has gone beyond return. With so many people with the “same/similar names” and, in some cases, people with the “same name and date of birth”, the SSN is the only intangible non-bio identifier that the private sector can rely upon to aid us tracking a person’s whereabouts, the assets of a judgment debtor, the employment and/or identity of a skip, to name just a few examples of the many types of investigations PI’s conduct for consumers, businesses, large companies, the indigent, and the wrongfully accused. Unless PI’s are given alternative options to replace the SSN identifier as a tool from our toolbox, our effectiveness will suffer grievous circumstances, which will subsequently trickle down to the consumer, the taxpayer and alas the economy as a whole.. The SSN is to PI’s, what DNA and FPC Henry (fingerprints) are to law enforcement. PI’s nationwide stand united against identity thieves and persons who use others’ identities to commit malfeasance. PI’s nationwide are also concerned about personal privacy; however, the answer is not in the SSN. The answer is in the punishment of the perpetrators who use SSN’s to conduct their illegal activities. I urge you to consider this argument in favor of an exemption allowing PI’s access to use SSN’s in our investigations. Anything short of an unbridled exemption would be contrary to logic, practical application, and a blow to commonsense. Thank you.