| Comment Number: | 531096-00235 |
| Received: | 9/4/2007 12:24:02 PM |
| Organization: | American Investigative Services, Inc. |
| Commenter: | Jay Groob |
| State: | MA |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
As recently retired Chairman of the Council of International Investigators, long-standing member of INTELNET, NALI,LPDAM, IAATI, LPDAM and NCISS, and a licensed Private Investigator in Massachusetts, New York, and New Hampshire, I strongly urge the FTC to seriously consider the negative impact of restricting or prohibiting the use of SSN's for legitimate purposes by licensed private investigators. SSN driven databases are a critical component in providing services to insurance companies, law firms, employers, and the general public that include criminal pre-employment screening, insurance fraud, criminal defense, and locating judgment debtors, deadbeat dads, missing heirs, runaways, and unclaimed property, to name but a few. To prohibit or restrict the use of SSN identifiers by licensed private investigators would have a severe negative impact on the accuracy and effectiveness of positively identifying individuals and conducting due diligence. As names and dates of birth are no longer definitive in identifying individuals, the SSN has become the primary identifier which private investigators use in the vast majority of assignments. To restrict or prohibit the use of SSN's by licensed private investigators would deal a serious blow to the profession, effectively rendering us unable to provide the very services the private sector relies upon which are not available through law enforcement, and which depend on our ability to positively identify individuals via SSN verification. SSN searches via proprietary databases are the cornerstone of the private investigation profession. Some of these database providers are already restricting the use of SSN's as identifiers by providing only the first five digits. Although helpful in narrowing down the list of potential subjects, this redaction of the complete SSN has greatly decreased the effectiveness of these tools, requiring additional cross-referencing of a number of sources in order to make a positive identification. Additionally removing SSN"s would create a substantial Burdon on indigent defendant's and other client's who would have to bear the cost of untold investigative hours of research to identify witnesses.etc. In sum, we believe that the prohibition or restriction of SSN data to private investigators would not only create additional hurdles to the positive identification of individuals so necessary to the profession, but would, in fact, give the unscrupulous an undue advantage in the continued perpetration of fraud and identity theft. We therefore respectfully urge the FTC to provide full exemption to licensed private investigators with regard to the use of SSN's in our investigations. Jay Groob President American Investigative Services,Inc Council of International Investigators