|Received:||9/10/2007 12:47:38 PM|
|Organization:||Alexander Toia & Company, LLC - Professional Investigations|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:As a licensed private investigator and business owner the past 25 years, it is imperative that all private investigators nationwide have access to SSN's in order to effectually conduct our jobs for civil and criminal defense oriented business. A large portion of our assignments include locations of missing persons for insurance carriers that need to communicate with its insureds, drivers, and witnesses, and produce them for depositions and trials. We also work for law firms that have a variety of legal issues, and social security numbers facilitate our work. They confirm the identity of subjects that are the focus of investigations. Where clients have obtained court ordered judgments, we need to locate debtors to identify where they are currently residing as well as find sources of revenues and assets from which to satisfy the judgments. A social security number is mandatory for these searches. In lost or abducted children cases, I have needed and used the social security numbers of suspected felons, including parents, to track the whereabouts of the adults, which have enabled us to locate the children and arrange for safe return. In background investigations where common names are provided, we need a SSN to authenticate the identity of the person being targeted. This is essential in determining a suspected fraud in an insurance related matter. In estate cases where attorneys need to locate heirs, or identify relatives when someone has died intestate, the SSN is most helpful in sorting through common names in order to pinpoint the people that legally qualify for the inheritance. In commercial cases for lawyers the SSN is needed to identify businesses owners where questionable activities have occurred, or to located someone who has defaulted on a business loan. Also, in alimony cases, especially in NJ where cohabitation can nullify future payments, SSN's are necessary to determine where people live and for how long they have been together. Without access to social security numbers, our job a investigators becomes increasingly more difficult, and it places a more costly burden on our clients to obtain legal information to support their legal cases. My firm works exclusively for law firms and their clients, and all information we obtain is held in strictest of confidence. Abuses occur in every facet of society - just look at New Jersey politicians for the number of crimes and frauds they have perpetuated over the years. Having worked in Law Enforcement earlier in my career, it is my firm belief that those who have the training and knowledge to utilize specific personal information, such as SSN's, Dates of Birth, Drivers' Licenses, Bank Accounts, etc., should be held at a higher standard with greater accountability, responsibilities, and sanctions than the general public. Not only is our work absolutely imperative to maintain smooth operations of the civil and criminal defense justice systems, in order to do so, we need to have access to personal records and identifiers to keep this system running efficiently. Take away our service to society and see how difficult and long it will take to keep it running. It would virtually shut down.