|Received:||9/6/2007 10:49:07 AM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:I operate an employee screening company and we conduct background checks for private and public companies as well as Government entities. Our only method of linking an applicant to a criminal record is by DOB and Social Security Number. If we have a name, DOB and SSN match the criminal offense is documented and reported to the potential employeer. If we can verify records by name and DOB only the applicant records will be reported and the applicant must then dispute the report and this will cause a delay in hiring and potentially unintended negative consequenses such as suspicion that the applicant has a criminal record. The proposed legislation would have no effect on Law Enforcement because they will have access to personal identifiers. Private companies will be at a distinct disadvantage if access to personal identifiers is prohibited. I believe there should be some credentialing process that would exempt qualified employee screening companies from any law that bars access to or redacts identifiers from public records. I recognize the growing problem of identity theft and the need to protect an individuals SSN however are we not substituting a greater problem by potentially employing dangerous individuals in the workforce. I know if I were a carreer criminal and I knew a background check could not be confirmed by a SSN I would protest andd threaten legal action until I got the job. This legislation is another bureaucratic blunder that without some relief to legitimate entities could eclipse any identity theft issues.