Comment Number: 531096-00230
Received: 9/4/2007 12:28:29 AM
Organization: A. L. Farr & Associates
Commenter: Alwin Farr
State: WA
Agency: Federal Trade Commission
Rule: Private Sector Use of SSNs
No Attachments

Comments:

Dear Sir or Madam: This last February marked my 40th year in the business of investigations. I have found it necessary to utilize individual social security numbers thousands of times in order to properly conduct inquiries including but not limited to: homicides, missing persons, kidnappings, cases involving varying types of fraud and counterfeit matters and all manner of trial preparation functions. Briefly stated I would have to close my business if social security numbers were eliminated from the limited tools available with which I conduct my investigations business. I am all in favor of limiting the access to social security numbers to law enforcement personnel and LICENSED private investigators. Beyond that I believe even the licensed private investigators should be compelled by law to not, under any circumstances, divulge the social security number to anyone; the only exception being a court order. I personally do not divulge the number under any circumstances, even to my attorney clients. The only exception that comes to mind would be if law enforcement demanded it, or if I received a court order I would certainly comply. I further believe that anyone outside law enforcement and/or licensed private investigators who illegally or improperly obtain and/or use social security numbers should be punished to the fullest extent of the law. In other words, punish the wrongdoers who improperly use and/or divulge social security numbers; but please ..... do not punish the legitimate licensed private investigtors. In the past six months alone I have sucessfully closed more than 25 cases, from the relatively minor to major matters. The positive conclusion to each was in some way based on the location and verification of individuals via their social security numbers. No less than 200 family members, friends, and associates were positively affected by my success in these cases. Please, please consider the needs of the public regarding this issue. Imagine locating or at least verifying the identity of a "John Smith" or even a "Steve Allen" without the aid of a social security number. Legitimate investigators depend heavily on the access to this data. Law enforcement is rapidly gaining on the task of catching the wrongdoers, individuals who steal identities including social security numbers etc., in order to continue their illegal activities. As earlier stated, let them continue their pursuit of the scofflaws, and punish them accordingly. Thank you. Sincerely, Alwin L. Farr