|Received:||8/16/2007 9:10:28 AM|
|Organization:||Safe Harbor Resources 501(c)3|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:General: Safe Harbor Resources (SHR) is a child-protection nonprofit which screens employees and volunteers in youth-serving groups (YSG's), to prevent pedophiles from infiltrating staff and molesting the children. Topic 1: Professional background screeners use the SSN with full advance permission and consent of those to be screened. Screeners do not "troll" sources to learn the SSN. There is little alternative since most official records going back in time contain all or part of the SSN. The impact of state laws restricting SSN usage greatly increase cost to YSG's. Without full SSN there are many similarly named persons who would be disqualified, costing more to DISCERN which is the miscreant, and whether the same is the applicant being screened or not. This cost discourages screening and jeopardizes children. Topic 2: Professional screeners ALREADY HAVE THE SSN, and only use it to authenticate and match it for DISCERNMENT purposes only. The SSN should be masked, not truncated or eliminated from, electronic public records. Professional screeners MATCH SSN's, they do not TROLL OR MINE for them. Professional screeners should be afforded special access with an approval mechanism, to authenticate already-held SSN's so identity can be established economically. Failure to do this increases screening costs to employers, most of whom are nonprofit charitable organizations serving children and lacking funds for extra screening caused by SSN redaction or truncation. This causes such employers to attempt amateur in-house screening, a boon to socially skilled and technically sophisticated sexual predators who easily exploit hasty and clumsy attempts to "protect" online data from identity thieves. A background check WITH SSN's available can cost $50. Without SSN the employer gets a list of, say, twenty names, all similar to the candidate's, some of which have disqualifying offenses and most of which do not. It can cost $250 to explore all twenty names via other methods to DISCERN that the one with disqualifying convictions IS or IS NOT the candidate. Employers find it cheaper to not screen at all, rather than risk worker retaliation over mistaken identity. Topic 3: Screeners do not use the SSN as an internal identifier because it is so commonly faked or mis-keyed. Topic 4: Fraud is what sexual predators commit when infiltrating YSG's in order to molest the children there. Where SSN's are eliminated from vital criminal arrest or conviction records, especially for sex offenses, it costs more to DISCERN which of several-to-many similarly-named individuals is the miscreant. The increased cost discourages screening, which in turn increases the risk-exposure of the children to infiltrated predators. Topic 5: Professional screeners take elaborate countermeasures to avoid being exploited by identity thieves, because the records data in screeners' possession is valuable. Employers who are discouraged by cost increases propelled by SSN redaction, attempt amateur in-house screening, mishandling and misinterpreting SSN data, and thereby screening-OUT good applicants because they cannot afford to DISCERN which among many similar-named persons is the miscreant. Identity thieves are assumed to be seeking money. Some steal identities in order to impersonate a namesake with a clear background in order to get screened-IN by naive employers discouraged by increased screening costs from clumsy SSN redaction. THIS JEOPARDIZED CHILDREN IN YOUTH-SERVING GROUPS. Conclusion and recommendations: The full SSN should be masked within, not eliminated from or truncated in, official records posted electronically for public access. Legitimate professional background screeners such as accredited members of the National Association of Professional Background Screeners, www.napbs.com, should be afforded means to be approved for batch access to the full records data, with unmasked SSN's for the purpose of MATCHING, NOT FETCHING, SSN's for authenticaton.