|Received:||9/4/2007 10:35:42 AM|
|Organization:||Trace Investigations, Inc.|
|Commenter:||Don C. Johnson, CLI, CII|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
|Attachments:||531096-00232.pdf Download Adobe Reader|
Comments:Professional private investigators need access to SSNs in the normal course of legal business activities; including, but not limited to, when providing litigation support services to attorneys and corporate counsel. Access to SSNs, as far as federal regulations are necessary and warranted, could easily follow the model established with the Drivers Privacy Protection Act, in that a permissible purpose must be present and the user (the investigator, for example) must be a pre-qualified subscriber to access. With that in mind, SSNs should not be accessible on the Internet to the public at large, absent these controls. I have attached case studies of the value of the SSN in pursing civil fraud investigations and other business matters. Thank you.