|Received:||8/16/2007 3:52:32 PM|
|State:||Outside the United States|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
|Attachments:||531096-00117.pdf Download Adobe Reader|
Comments:My first comment is the obvious: SSNs is the de facto universal form of identification. If we didn't have SSNs, people would be calling for a national ID similar to SSNs to prevent ID Theft and fight terrorism. The problem is not SSNs but the fact that SSNs like most/all other IDs are not secure and therefore open to ID Theft and abuse. There is no guarantee that replacing unsecured SSNs or limiting its use with another equally unsecured identifier or authenticator will reduce overall ID Theft. The suggestion of using an alternative identifier or authenticator with the same weaknesses as SSNs (without security) has no valid security, scientific or logical justification or guarantee that ID Theft will decrease. The reason why many are suggesting that we replace SSNs with an alternate identifier or authenticator is because of our failure to secure SSNs and our failure to understand and eliminate ID Theft. If we can secure SSNs, then the suggestion of phasing out SSN use is moot. We at Virgin ID have that MAGIC BULLET!