Obtaining Customer Social Security Numbers (a follow up), by Michael Dennis

In the upcoming meeting in September in Las Vegas, I plan to explore why, when and how attendees are using social security numbers they request on their credit applications. My assumption is they use Social Security Numbers (SSNs) to obtain consumer credit reports which become part of the decision process about extending credit B2B to entities such as sole proprietorships and partnerships. But that assumption could be wrong.

Along the same lines, I assume that every CMA member company that obtains SSNs knows about the overlapping state and federal laws that address the duties and obligations of companies that obtain SSNs from applicants. And maybe this assumption is inaccurate.

I also assume that if a creditor company obtains a SSN or a consumer credit report, that there are detailed written policies and procedures about how this information is going to be stored and safeguarded and ultimately destroyed.

In addition, I assume that CMA members understand their legal obligations relating to reporting unauthorized access to this type of information, and that members have budgeted or reserved for [or alternatively purchased some form of insurance to cover] the potentially massive costs associated with a data breach.

What assumptions do you take when asking for SSNs? Or even better, when you’re included as a trade reference, do you provide your personal number to the reporting agent? As always, I welcome your feedback.

Michael C. Dennis is the author of the Encyclopedia of Credit, a free, fast, internet resource for credit and collection professionals. He is a frequent instructor at CMA-sponsored educational events. His most recent book, “Happy Customers, Faster Cash,” is available at amazon.com. He can be contacted at 408-204-0129.

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