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Old January 22nd 07, 08:20 PM posted to rec.radio.amateur.policy
Paul W. Schleck Paul W. Schleck is offline
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First recorded activity by RadioBanter: Jul 2006
Posts: 74
Default Social Security Numbers, the FCC & the ULS

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In Joaquin Tall writes:

Hello All,


I was about to take my "tech" exam this coming Saturday, which I was
really looking forward to doing. I have been interested in radio for
some 45 years; the last few months, hams buddies have encouraged me to
finally do something about not waiting a 46th year.


I went to the ARRL's site he


http://www.arrl.org/fcc/uls-qa.html


My first and immediate concern was that I had to supply my SSN in order
to apply for a ham license. Why? It is part of the "Debt Collection
Improvement Act" of 1996. What possible debts would be incurred by me
becoming a ham, that the FCC would need to utilize my SSN to collect?
Failure to renew my license!? Did I have an option?


[...]

Alan,

I absolutely 100% agree with the sentiments expressed. So does the
ARRL, and probably the majority of licensed amateur radio operators.
No, you don't have an option if you wish to obtain an amateur radio
license, unfortunately. Even though the FCC publicly tracks licensees
with the FCC Registration Number (FRN), it is still mapped back into an
SSN in their non-public database, as you note. The FCC is following the
letter and intent of the above-mentioned Act. Hypothetically, one might
owe debts to the government in the form of unpaid taxes, or be liable
for child support (previously a state matter, now federalized under this
Act). The government wants to be able to better track such individuals,
and withhold licenses or fee refunds from them. However, such an
overreaching Act does not take into account the record-keeping burdens
and potential for privacy violations that may be out of proportion to
whatever benefits may be obtained. Applying this Act to amateur radio
licensees, though lawful, strikes me as one of the least beneficial
circumstances relative to the costs.

[...]

I am not calling into question the honesty or integrity of the VE's or
the ARRL, at all! That is not the reason for my concern. In order to
register with the ULS [and apply for a ham radio license], you've got
to submit your correct SSN number. My concern lies with the necessity
of giving out my SSN to another government institution that cannot
guaranty its confidentiality or safety. Just last year the Veterans
Administration notified 26 million vets that their data, including
SSN's had gotten "lost".


[..]

Even more disturbing is the results of an annual government privacy and
security report card given by Congress, based on Government Accounting
Office findings:

http://www.house.gov/list/press/fl02...nicholson.html

The FCC isn't listed, but I doubt that it would get an A+ under this
grading system. The average grade over all agencies, as of 2005, is a
D+.

[...]

I am planning to write to the ARRL & the FCC for some guidance in this
matter. If, however, there is no way to register with the ULS without
submitting my SSN, I will need to rethink, deeply, just how much
becoming an amateur radio operator fits into my life.


The ARRL will point out that they did petition the FCC, giving many of
the arguments that you just did (privacy invasion, unwarranted and
costly collection of information relative to any possible benefit, etc.)
and were rebuffed. If the FCC replied to you at all, they would just
point out that they are following the laws passed by Congress, and as
written.

Like many hams, I was faced with the decision at renewal time whether to
give the FCC my SSN, or give up my ham radio license. I didn't want to
give up my ham radio license. Furthermore, I don't think that mass
refusal by hams to give SSN's, and thus give up their licenses, would
alone solve the problem. It might instead do great damage to the
Amateur Radio Service by significantly reducing the number of active
hams who are knowledgeable of, and active in, regulatory politics. It
would also prevent individuals like yourself from enriching our hobby by
your inclusion as a licensee. I do hope that you will reconsider.

I don't think that the situation is hopeless. The weaknesses of
computer security at many government agencies, and the poor choice of
the SSN as both an identifier *and* authenticator, are clearly both
coming to a head, and may have better political/legislative solutions,
hopefully within our lifetimes.

- --
73, Paul W. Schleck, K3FU

http://www.novia.net/~pschleck/
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