Uses of Social Security Numbers in the Private Sector: Why SSNs Are Not Appropriate for Authentication

The SSN has evolved since its establishment in 1935 and implementation in 1936 to be used as both an identifier and an authenticator. 

This morning, we heard from a panel of experts on the use of the Social Security number as an identifier.  As an identifier, the SSN is provided by individuals to answer the question, “Who are you?” As an authenticator, the topic of this panel, the SSN is provided by individuals in response to a challenge: “Prove who you are.”

Comments to the Federal Trade Commission: Prerecorded Telemarketing Calls to Existing Business Customers (EBR)

For years intrusive, privacy invasive telemarketing calls have been a major source of consumer outrage.  Calls made by so-called “predictive” dialers -- automatic dialing that allows a telemarketer to call multiple households at one time -- have been a significant consumer complaint. Such calls are intrusive, invade the privacy of one’s home, and result in great annoyance when one races to answer the phone to find only dead air or a hang-up on the other end of the line. Predicative dialer calls are particularly troublesome and potentially dangerous for the elderly and the disabled.

Prerecorded Telemarketing Calls: The Need for Industry Reform

VMBC petitioned the Commission to amend the TSR to allow prerecorded telemarketing calls to consumers when the caller has a claimed business relation. If accepted, an EBR exception for prerecorded sales calls would have created a major loophole, opening the door for a dramatic increase in unwanted calls to consumers who had placed their telephone numbers on the national Do-Not-Call (DNC) Registry.

Comments to FTC on National Credit Reporting Agencies and Free Reports: Credit Reports Most People Have Never Heard Of

We urge the Commission to study national consumer reporting agencies sooner rather than later and to issue regulations giving consumers' access to free reports. In our 12-year history we have received many complaints from individuals who have been harmed or otherwise disadvantaged because of erroneous or inappropriate information in such consumer reports.

Financial Privacy Notices: Shorter is Better

For business, the goal should be not only to provide a notice that satisfies the legal requirement, but one that consumers can easily understand. Although practices may vary from company to company, the bottom line is always the same: Companies either share information with affiliates and third parties or not. Consumers either have the right to opt-out or they don't.

Comments on HHS Request for Information: Voluntary Storage of Personal Data in Preparation for Emergencies

The notion of a 21st Century vault for storing personal data for emergency use has a great deal of initial appeal. However, just below the surface lurk multiple concerns about the ability of any existing system -- or even one that could be constructed -- to ensure the public has adequate data privacy and security.

Consumer Group Analysis of House FCRA Legislation, H.R. 2622

This memo provides a section-by-section analysis of H.R. 2622, which was reported out of the House Financial Services Committee on July 25th. Although the bill takes some steps to prevent identity theft, improve accuracy and protect medical privacy, it fails to offer meaningful solutions to the most important problems that were identified in Senate and House hearings, especially given that the quid pro quo for these measures is permanent and perhaps expanded preemption of state laws.

Letter to House of Reps. and Senate to Oppose HR 2622

The Privacy Rights Clearinghouse and the Identity Theft Resource Center urge you to oppose H.R. 2622 as written because it preempts many state consumer protection laws while failing to prevent credit bureau mistakes or stop identity theft.

Comments Submitted to the Internal Revenue Service: Disclosure and Use of Tax Preparation Data Notice 2005-93 and REG-137243-02

At no time is one's expectation of privacy greater than with tax preparation. The proposed rules address privacy concerns in some important ways by requiring consumer consent where none was previously required. At the same time, the rules open the door for far more insidious privacy invasions by allowing tax return information to be used for marketing and shared by preparers with "any person."

Comments Regarding the Use of Personal Medical Data by Financial Institutions

The proposed rule generally prohibits a creditor from obtaining and using medical information for making decisions about a consumer's credit eligibility. The rule then makes an exception that allows creditors to obtain and use financial information that happens to be related to medical debts, expenses and income.


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