|Received:||8/3/2007 4:58:32 PM|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:SSN is routinely used as an identifier and password for business use. Every business should be required to assign a non-SSN identifier and develop non-SSN identification verification methods. Businesses without a specific requirement to have the SSN on file (such as financial institutions or businesses required to make tax reporting requiring the SSN) should be required to remove it and any derivable or encrypted form of it, from their records. Businesses with a temporary need for the SSN (such as credit report review) should be required to remove the identifier after a certain time period. If the use of the SSN is later required, the business should be required obtain it from the consumer directly. Credit reporting agencies should develop their own identifier instead of using the SSN. This will lessen the need for other businesses to require the SSN.