|Received:||2/22/2007 12:51:20 PM|
|Agency:||Federal Trade Commission|
|Rule:||Proof Positive: New Directions for ID Authentication|
Comments:As this topic is discussed, please consider not only on-line (Web sites, email, Instant Messaging etc.) applications, but also authentication over the phone. Companies rely heavily on phone calls to provide service to their customers, both in person and through Interactive Voice Response (IVR) systems. The efficiency of this communication channel is dependent on making it easy for the consumer to authenticate themselves in a manner appropriate to the channel and technology employed. The phone channel should not be expected or required to use authentication methods designed for on-line applications. One of the most common authentication methods over the phone is to ask the consumer to provide the last 4 digits of their social security number (SSN), which is then matched to the SSN the company has on record for their customer. This works especially well in an IVR application where the customer interacts through their phones numeric keypad using touch tones. I urge the commission to preserve the right to use this technique rather than overreact to fears of identity theft involving the entire SSN. There is no other piece of numerical information that uniquely identifies an individual, and this appropriate use of only the last four digits of the SSN allows phone service, especially using an IVR, to be a universally accessible and efficient option. While some may promote the use of speech recognition systems by contending they allow for other authentication schemes such as voiceprint matching, such systems are costly and not widely deployed. They also lack the reliability of touch tone input...if you don't believe me, just try calling your airline or travel service from a busy airport and attempt to navigate the system using spoken responses. Inevitably, you will need to use your keypad or just opt to speak to a person. Efficient and easy to access customer service is expected by the American consumer. Please do not make this difficult for a company to deliver by enacting unnecessarily burdensome regulations.