|Received:||8/9/2007 7:27:57 AM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Working for a hospital that currently relies on the SSN to ensure that it can correctly match a patient to his or her information, I believe that the entire debate regarding the use of the SSN has missed the core issue. As you can hopefully appreciate, immediate access to complete information is crucial to ensuring that a patient is properly treated. Often, the SSN is the only unique identifier that a patient remembers. The core issue is that financial institutions, in their lust to quickly grant consumers with credit, have created an environment where an individual can quickly get credit simply by providing his/her name, address, date of birth and SSN. The effect of financial industry's decision is to create an environment in which the consumer must be hyper-vigilant about the release of personal information. The impact is that organizations that have a bone fide need to use the SSN, must take extraordinary steps to protect information or to elimnate the use of identifiers like the SSN (which in the case of a hospital may result in an impact on patient care). If you want to address the problem, then you must address the manner in which financial institutions grant credit. As an alternative, you need to place the entire financial burden associated with a case of identity theft on the financial industry. In any case, the financial industry caused the problem. I beleive that it should be up to the financial industry to either solve the problem or bear the costs associated with its decision.