The following is a rough draft to be used on the online comments portion of Utah's
Bureau of Criminal Investigation webpage. Any helpful suggestions regarding wording and formatting would be appreciated. I will also be sending a comparable communication to Utah's Attorney General with regard to this matter and will indicate to BCI that I have notified his office.
"With regard to the application forms available online for both the ORIGINAL CONCEALED FIREARMS PERMIT and FIREARMS PERMIT RENEWAL applications I see that a SOCIAL SECURITY NUMBER (SSN) is REQUIRED.
I don't see any indication in the Utah State Code
U.C.A. 53-5-704 covering Conceal Firearms Law any authorization from the State Legislature to requiring the disclosure of one's SSN for a Concealed Firearms Permit.
The instructions for each form indicate that ANY unanswered portions will result in the application not being processed. I understand that this is a FEDERAL PRIVACY ACT violation and places UTAH in LEGAL JEPORDY.
Section 7 of PL 930579 [the Federal Privacy Act of 1974, 5 USC 552a note]
Sec. 7 (a)(1) It shall be unlawful for any Federal, State or local government agency to deny to any individual any right, benefit, or privilege provided by law because of such individual's refusal to disclose his social security account number.
(2) the provisions of paragraph (1) of this subsection shall not apply with respect to--
(a) any disclosure which is required by Federal statute, or
(B) any disclosure of a social security number to any Federal, State, or local agency maintaining a system of recoreds in existence and operating before January 1, 1975, if such disclosure was reuired under statute or regulation adopted prior to such date to verify the indentity of an individual.
(b) Any Federal, State or local government agency which requests an individual to disclose his social security account number shall inform that individual whether that disclosure is mandatory or voluntary, by what statutory or other authority such number is solicited, and what uses will be made of it.]