|Received:||9/5/2007 1:51:30 PM|
|Organization:||Exceptional Investigation Services|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:I am retired from the New York State Police after a twenty year career, including assignment to Internal Affairs, and understand the issues of protecting the public from identity theft. I have relocated to Richmond, VA and am now a licensed Private Investigator and owner of a Private Investigation Firm. The legislation proposed is good as far as it goes, however, whenever exempting law enforcement an exemption should also be given to Private Investigators. The ability to identify persons, with certainty, when conducting a criminal investigation for the defense of persons charged with committing crimes is imperative to a fair trial. The police, prosecutors, and government have access to many resources unavailable to private citizens. In Virginia we are licensed and regulated by the State. Therefore should an abuse of authority take place, such as selling social security numbers & information, an oversight agency is already in position to mandate sanctions. Many times I am asked to locate relatives, missing persons, deadbeat dads and other people. The only way to identify these persons from a pool of potential candidates with the same name is by SSN. I also routinely perform background checks on employee candidates for small businesses and criminal history checks as well. I am not advocating that SSN's not be protected. I am only asking that PI's be exempted, the same as law enforcement, so we may continue to serve the public and their best interests.