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FTC SSN Workshop–What’s It Mean?

Posted by Bill on December 13, 2007

  ftc-web.jpg     The FTC had a two day workshop “to explore the uses of Social Security numbers in the private sector and the role of SSNs in identity theft.”  The workshop is part of the work of the President’s Identity Theft Task Force to reduce “unnecessary uses of the SSN.”   Various groups and individuals attended the workshop representing government, private business and consumers.  The focus of discussions was how SSNs are used by business and the government and how limiting access to a person’s SSN will prevent identity theft.  There was a lot of discussion defining and distinguishing use of the SSN as an identifier and an authenticator, how the SSN is used as such, and what alternative means of using the SSN as an identifier/authencator is available. 

Some consumer groups and private groups believe that the SSN should not be used for an identifier/authenticator, and that a different of identifying identity should be implemented.  The business and industry groups talked about how they use the SSN as identifying people and their related accounts and information.  It is clear the SSN is used to match and identify different people with various amounts of information.  The SSN is tightly woven into use as a national, unique identifier for records matching and internal and external reports.  The government requires that the banking, insurance and credit industries report information utilizing  the SSN.  But, as one panelist said, “The SSN is out there. You can’t take it back.”  My conclusion is much the same.  Some businesses, institutions and government agencies need to retain use of the SSN as a unique identifier.  This simplifies matching matching information.  I am sure the IRS is not going to stop using SSNs as its taxpayer identification number.  Banks and other income generating businesses will probably be required to report income to the IRS and other government agencies using the SSN.

According to Consumers Union, there are three bills pending in Congress to limit the use, sales and purchase of SSNs.  See SSN BillSummary.  I do not believe the private investigation industry is concerned about whether the SSN continues to be used as an identifier or authenticator.  The industry is more concerned about the exceptions in the bills being considered restricting the industry’s access to SSNs for legitimate investigative purposes.  The bills provide exceptions to use, sale or purchase of SSNs to law enforcement, for purposes of national security, public health, complying with state or federal tax law and several other exceptions.  There is no exception for litigation matters, insurance investigations, fraud investigations, missing persons investigations or any other legitimate business investigation.  This means that private investigators could not properly identify persons who are subject to an investigation or identify witnesses needed in an investigation.

The Graham-Leach-Blilley Act and the Drivers Privacy Protection Act restrict certain personal and private information access, but both laws provide exceptions for litigation matters, fraud matters and other legitimate investigations.  The same exceptions should be provide for in any legislation restricting access to SSNs.  The Federal Trade Commission should consider recommending such exceptions in their report to the President’s Identity Theft Task Force.  Legitimate investigations, being litigation matters, fraud matters, criminal defense matters, missing persons matters or buisness matters, should be named as an exception to restricting access to SSNs.

Bill Lowrance

President PIAVA

president@piava.org

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