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<tr><td><b>Comment Number: </b></td><td>531096-00337</td></tr>

<tr><td><b>Received: </b></td><td>9/10/2007 12:30:23 PM</td></tr>

<tr><td><b>Organization: </b></td><td>N/A</td></tr>

<tr><td><b>Commenter: </b></td><td>Elizabeth Johnson</td></tr>

<tr><td><b>State: </b></td><td>NY</td></tr>

<tr><td><b>Agency: </b></td><td>Federal Trade Commission</td></tr>

<tr><td><b>Rule: </b></td><td>Private Sector Use of SSNs</td></tr>

<tr><td>No Attachments</td></tr></Table>

<hr><P><b>Comments:</b></p>September 05, 2007


The Honorable Deborah P. Majoras

Federal Trade Commission

Room H-135 (Annex K)

600 Pennsylvania Avenue, NW

Washington, DC 20580


Re: Comments Regarding “SSNs in the Private Sector

Comment, Project No. P075414”


Dear Chairwoman Majoras:


Please consider the following for legislation:


To reduce the use of SSNs for Identity Fraud as well as illegal use of very personal information in the hiring process by employers…the law should be amended to specify that SSNs be obtained and used by an Employer only after a job offer has been made to an applicant.  SSNs should not be requested in the pre-hiring process.


Too much very personal information can be potentially derived about the applicant regarding their lifestyle, civic associations, religion, marital status, medical history and other restricted information that may be applied illegally to the employment decision by an Employer.


A job offer should be based upon only that information derived from an interview (by phone or in person) and the contents of a resume and/or cover letter and/or references submitted by the applicant. After the job offer…then the employer may obtain the SSN for credit report, background check and other uses.


Refusal or disqualification of employment can then be more clearly defined by the Employer and attributed to information derived from the credit report, background check and reference check.


Authorizations for credit and background checks should be procured, signed and dated by the applicant after the interview occurred and a firm offer of employment has been presented to the applicant in writing.


By changing the current process we achieve three important objectives; 

1.) We limit access and use of every applicant’s SSN.

2.) We help alleviate any doubts concerning the stated reasons for disqualification for employment.

3.) We help preserve the security of a person’s identity and access to their financial, medical and legal history by restricting access to an applicant’s social security number and personal profile and history…until a definite employment offer is made.


Thank you,


EC Johnson


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