|Received:||8/2/2007 11:47:54 AM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:The social security number is the essential ingredient for identity theft. Right now the use of social security numbers by the private sector allows identity thieves easy access to this number. The following steps should be taken to help reduce the problem- No business or entity should be allowed to use or retain in their records any social security numbers unless there is no other way to accomplish their business purpose. In order to police the validity of a businesses decision to use or maintain social security numbers in their operation. a mechanism needs to be established so that if an individual or the FTC can challenge a businesses decision to use social security numbers. Any business that retains social security numbers should be required to encrypt the numbers maintained in their records. A complete audit trail should be maintained of any employee that accesses a social security number. Civil and criminal penalties should be established for businesses that fail to take the required safeguards with the social security numbers. Civil penalties to those persons harmed are critical to economically motivate businesses to comply. Additionally any business who fails to properly safeguard and encrypt social security numbers should be required to pay the reasonable costs incurred by an individual that becomes a identity theft victim as a result of the businesses failure to properly safeguard the data. Significant additional law enforcement resources at the Federal level should be devoted to identity theft to make it less "profitable" for criminals to engage in that activity.