|Received:||8/27/2007 11:07:58 AM|
|Organization:||Secure Systems Group, Ltd|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Our company provides litigation support to law firms and conducts Due Diligence and Employment Background Investigations for various clients. The ability of our company to locate and interview potential witnesses in civil and criminal proceedings relies heavily on our ability to access public record sources that contain SSN and DOB information associated with the names and current/former addresses of named individuals. SSN and DOB information are the only unique identifiers that enable anyone to positively identify and locate a particular individual, and if our access to SSN information is eroded any further, we will be unable to provide investigative services. Anyone familiar with our legal system should realize that the vast majority of investigations into embezzlement schemes, stock manipulation, investment schemes, real estate schemes, workers compensation fraud, and other white collar crimes are performed by private sector firms like ours. Our cases may eventually trigger a federal or state criminal investigation, but without our services, most white collar and corporate crimes would go undetected. Companies like mine also provide all of the investigative support to the criminal defense industry, and without access to public records containing SSN information associated with names and current/former addresses, we will be unable to locate and interview the witnesses that defense attorneys need to support their client's at trial. I completely understand the public's concerns about identity theft, but your agency and the public should understand that the only defense against identity theft is a public policy that allows employers, banks, credit agencies, and merchants full access to an accurate federal identification system that associates the SSN and DOB with a current passport photograph of the individual. The only way to safeguard the identity of our citizens is to create a uniform identification system that everyone can access. Preventing public access to the only current national identifier (SSN) only makes the criminals job of changing his identity easier, it does not safeguard anyone.