|Received:||9/4/2007 11:21:54 PM|
|Organization:||Investigative Research Specialists, LLC|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:My comments are made with reference to SSNs In The Private Sector - Comment, Project No. P075414. Social Security numbers are a vital secondary identifier used by private investigators to correctly identify people every day. Our clients, ordinary citizens, small business owners, and large corporations, call on private investigators for many reasons. Without access to social security numbers it would be nearly impossible for investigators to differentiate between persons with the same names. While dates of birth are useful, they are not assignable or unique. It is possible for persons of the same name to also have the same date of birth. Private investigators use social security numbers to identify dead beat parents, investigate product counterfeiting operations and theft of intellectual property, locate debtors, missing persons and persons with stolen property. Private investigators are often called upon to investigate the background of prospective employees, nannies and elderly care givers. Employers are very concerned about hiring persons with criminal backgrounds. The social security number is a unique identifier that enables the private investigator to report accurate criminal histories to managements. Businesses today suffer losses from fraud in the billions of dollars each year. Business owners hire private investigators to provide due diligence in order to make sound hiring and partnership decisions. Not being able to identify the criminal history of a prospective senior manager or strategic business partner can have a devastating effect on a company.