|Received:||8/31/2007 11:37:56 PM|
|Organization:||PM Investigations, Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Greetings: It’s extremely important to evaluate the use of SSN by private investigators. First and foremost, PIs in most states have licenses that require nearly the same procedures as Law Enforcement – finger prints, background checks, and insurance. I know this – as I spent 10 years as a police officer before opening my own agency. I learned quickly how over tasked law enforcement is when the complaints rushed into my office from the private sector saying how law enforcement can’t spend the hours on cases looking for an ex-spouse who is obligated by our courts to pay support. Without the SSN and when the client comes to the office looking for help (and often bringing the 2 ½ kids with them), we’ll have to send them over to DEFAC for food support since the “locate” failed. I’ll bet the number of dead-beats increase if PIs can’t use the SSN as part of our tool belt. The above is just one example. Others would be serving someone legal papers and the only thing that makes the “locate” easier is that nine digit number. The problem is not with the Private Investigator…as the data sites we use logs our activity for audits. The real problem is the criminal refusing to live up to the responsibilities the court has order. If we remove this tool from licensed private investors – the criminal will win again. I as a business owner have learned the name of the target isn’t enough to locate. The address is no longer a method – since the “bad guy” just hides behind a room-mates name or skips around the country avoiding the responsibility. It’s reached the critical stage. If we give the ability for the bad guy to continue to hide – we all lose. On behalf of my industry - I urge you to consider this argument in favor of an exemption allowing PI's access to use SSN's in our investigations.