|Received:||9/4/2007 4:39:59 PM|
|Organization:||Special Investigations, Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:I am a licensed Private Investigator in Indiana. I conduct investigations categorized as Domestic Investigations, among other types. Many cases involve child custody matters where one of the parents is concerned about the other parents "friend" that has contact with the child when the child is visiting. A general background investigation of the "friend" will provide needed information that the child is not at risk when away from the concerned parent. In a recent case, it was determined that my client's ex-wife was dating a sex offender who was recently released from prison. My client by court order secured full custody of the child. Access to the SSN provided specific identification of the individual in question. In the same vane, some clients request a search for an old friend, male or female, in order to re-establish contact. Verifying that a search is being done for the correct individual, often a SSN is needed. One case involved a client looking for a old girlfriend who he had lost contact with shortly after WW II. The person was located and they subsequently met. The SSN was critical to locating the friend. These two cases involve some of the real world concerns the public has. They are not law enforcement issues. However, these matters are important to them. The public looks to the Private Investigation industry to fill the gap between law enforcement and themselves when information is needed. The use of the SSN and its access is the only identifier that is reliable at this time. As a major part of the FTC study, I recommend the FTC look at the number of identity theft issues involving licensed Private Investigators. I believe you will find that information provide by a PI to a client represent a small number of ID theft. I recommend the FTC review the background of the Private Investigators. I know that you will find that the vast majority are former law enforcement, intelligence types, and others who are worthy of the trust and responsibilty the public places on them. Most states license Private Investigators, require E & O insurance and are over-seen by state agencies. The FTC in their review should solicit information from those state agencies to determine the extent of misconduct by licensed Private Investigators. PI's serve a unique niche in the world of investigations and security. We are worthy of the public's trust.