|Received:||9/5/2007 9:58:07 PM|
|Organization:||PDJ / 1st Source Investigations|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments: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. 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.