| Comment Number: | 531096-00064 |
| Received: | 8/4/2007 5:21:33 PM |
| Organization: | |
| Commenter: | Hansberry |
| State: | NJ |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
Private sectors must justify the need for a SSN. Many still use it as a customer number or other identifier with no intention of actually using it to pull credit, which the consumer must give permissions for anyway. It should be illegal for many companies to retain the SSN of a consumer even after using it for valid credit approval purposes. Those that do need to retain it - like employers or banks - must justify the need and have regulations that strictly enforce how that data may be retained. In other words, the private sector needs to essentially apply for a license that will give them specific rights as to when they can ask for an SSN and when/if they can retain it after the use has been fulfilled, and for how long they can retain it. Those with a license must be subject to periodic and random audits with stiff penalties for failure to comply with regulations, and be liable for civil penalties when data has been compromised.