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Tenant Privacy & Landlords: Social Security Number

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Tenant Privacy & Landlords: Social Security Number

Postby Anna » Sat Apr 23, 2005 4:41 pm

April 24, 2005

Tenant Privacy And Landlords
By JAY ROMANO

A RULING by a New York State Supreme Court justice that an existing tenant is not automatically required to give a landlord his or her Social Security number has led to uncertainty among lawyers who represent landlords, tenants and even co-op boards in New York.

In a 17-page ruling on Feb. 28 rejecting a motion to dismiss a lawsuit brought by a tenant who was threatened with eviction if she failed to give her Social Security number to her landlord, Justice Diane A. Lebedeff of State Supreme Court in Manhattan also said that the landlord's claim to be entitled to the Social Security number as a condition of renewing the lease was deceptive.

Justice Lebedeff said in her ruling that the question was whether, in a relationship between two private citizens - a landlord and a tenant - the state's consumer protection law protected the tenant's Social Security number from disclosure as confidential information.

"A Social Security number is prima facie privileged information," the justice wrote, adding that "while the privilege must give way as required by statute, regulation or court order, in ordinary circumstances, the person who holds the Social Security number appears to be free to decline disclosure."

James B. Fishman, the Manhattan lawyer who represented the tenant, Ariana Meyerson, said the ruling clearly establishes that a landlord cannot demand a tenant's Social Security number unless there is an independent legal basis for requesting it.

Mr. Fishman said that the lawsuit was brought after his client, a tenant at 232 Elizabeth Street in Manhattan, received a notice from her landlord demanding her Social Security number and date of birth as a condition of renewing her rent-stabilized lease. Mr. Fishman noted that while the city's Administrative Code permits landlords to inquire about occupants, it does not authorize landlords to demand Social Security numbers.

Unable to determine why the landlord wanted the information, and concerned that releasing it could subject her to identity theft, Ms. Meyerson sued under the state's consumer practices statute.

Justice Lebedeff ruled that to the extent that the landlord made receiving the tenant's private information a condition of renewing the lease, the landlord's actions were "clearly deceptive," because the courts have held that a tenant's "mere nonresponse to a demand notice alone" is insufficient grounds for eviction. In addition, the justice ruled that the city's Administrative Code "does not authorize a demand for Social Security numbers of apartment occupants."

Eric Kahan, the lawyer who represented the landlord, Prime Realty Services, said that the case will now proceed to trial.

"The judge did not say that a landlord can never get this information," he said. "In fact, landlords have an obligation to get Social Security numbers when they are establishing security deposit accounts for tenants." (The judge noted that the landlord in this case did not have the number.)

Dov Treiman, editor of The Housing Court Reporter, said that landlords can almost certainly get Social Security numbers at the inception of a tenancy or even sooner - to comply with the security deposit requirements and to perform credit checks on prospective tenants.

Steven Shore, a Manhattan co-op lawyer, recently included information about the case in a newsletter to clients. "The scope of this decision is not clear," he said, adding that the ruling could apply to co-ops that request confidential information from shareholders.

"At a minimum, however, if a tenant declines to provide a Social Security number, a landlord or board should seek legal counsel before any further action is taken."

Copyright 2005 The New York Times Company
http://nytimes.com/2005/04/24/realestate/24home.html

4/25:
Sorry: it is a long decision and I forgot to review the post before I left. It exceeds TN's limit, so I've broken it up, below.

A showing of 'deception' is needed for claims under GBL 349 & here it is that her LL refused to renew her RS lease without her SS#, claiming he had a legal right to demand it. This is a frequent tactic used by LLs at renewal time: they include a dozen extra riders above and beyond the two allowed (window guards & lead paint). Yes, LLs can ask, no more than once a year, for the NAMES and relationship to tenant of all occupants, but nothing else: no salary, no SS#.

Why sue in Supreme Court instead of waiting to be sued for eviction by LL in HC? to avoid the blacklist & HC judges, for two...

<small>[ April 25, 2005, 09:11 AM: Message edited by: Anna ]</small>
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Robert Fortune » Sat Apr 23, 2005 9:30 pm

Aloha, Anna:

If I'm not mistaken, anyone can simply log onto the Social Security Administration's website and using just a person's name and general idea of their "pretty much guessed age" and get their social security number. I know I did it with a deceased relative having only some very basic information about them and in maybe 2-3 minutes I had their social security number. Aloha. Peace.

Lizard~King

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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Robert Fortune » Sat Apr 23, 2005 9:42 pm

Aloha, Anna:

Forgot another good one. There are online companies that anyone can pay to become a customer of and once you pay the $40.00 or so that they charge you can look up just about anyone's entire life history including every place they've ever been known to have lived, in any state of the US, whether they were ever arrested and for what and where, any and all schools they ever attended, and pretty much anything you or anyone might ever want to know and more about anyone.
For $40.00 a landlord could get access to as much detailed information about every single one of their tenants and all completely legal and from the comfort of your home sitting at your PC.
I tried the free sample searches option one site offered myself and I can tell you that it's quite accurate and went back as far as 50 years ago for the few people whose names I ran through their online database(s) including my own name. It listed where I lived when I was 5 years old and every just about every other place I've ever lived as far as the name of the city/town, schools, etc...
Of course a tenant can also use those same systems to check the history and background of their landlord and the LLs employees should they be so inclined. Aloha. Peace.

Lizard~King

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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Cranky Tenant » Sun Apr 24, 2005 12:13 am

Originally posted by LizardKing:
Aloha, Anna:

If I'm not mistaken, anyone can simply log onto the Social Security Administration's website and using just a person's name and general idea of their "pretty much guessed age" and get their social security number.

Even if this was true, which it's not, that's certainly not a reason why LLs would be entitled to Social Security numbers.

Online services may provide information on individuals with unique or unusual names but, without a social security number or some other unique means of identification, there's no way to identify individuals with more common names, like John Smith, Jose Rivera, etc.
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Robert Fortune » Sun Apr 24, 2005 9:13 am

Aloha,

It *most certainly* is true. Unless somehow I was able to get someone's social security number some 30 years after they were deceased. What, did I get it from them from beyond the grave? And this was someone who I never lived with after I was about 2 1/2 years old so there's no way I could possibly have known what their social security number was. I have their social security number right now written down. It was my own father. Aloha. Peace.

Lizard~King

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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Robert Fortune » Sun Apr 24, 2005 9:58 am

Aloha Crank Tenant:

I'm backkkk! I've just checked Social Security's online website which they've apparently updated since I last visited it a few years ago, but even now you'll see they've got an option to "Block password access" to your online social security information so they know that no computer system is fool-proof and I would venture an educated and experienced guess, that someone who wanted to could easily enough get information from their system.
Now as far as third party companies that *are* online and sell subscritions to anyone who cares to buy one from them to access their online databases and your belief that a person would have to have an unusual or unique name in order for someone else to know if they have say the right "Jose Torres". Not true. Cross-referencing.
The online records will have a complete history of where all the "Jose Torres" entries lived including, especially if the tenant has lived in the building any length of time, their current address, so them once you see the record that matches their current address you know you have the correct "Jose Torres" and Walla! Everything you ever wanted or cared to know about them and all from the convenience of your home or office at the touch of a key on your PC's keyboard.
But hey, if you still doubt me on this and care to put up say $100.00 to pay for the subscriptions to two or three of these online companies' databases and I assure you I'll be able to tell you more about your life history than you ever would believe anyone could possibly know and all before the sun goes down that day if not a lot sooner.
And when you subscribe to one of these online companies you can search on an unlmited number of people since you are paying for unrestricted access to their database(s) so for the same one subscription fee you can look up information on as many as 1000 or more people. Aloha. Peace.

Lizard~King

"I am not *ON* the Black list. I *AM* the Black list."
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Concourse » Sun Apr 24, 2005 10:04 am

Anna, that doesn't appear to be the full decision, as I noted that the judge's finding that the landlord was engaged in "deception" is not quoted in the text. Any chance you can post the remainder or provide a link to the text? thanx.

This is a good decision, of course, but a couple of things perplex me. What if the LL just gives the tenant a W-9 and says--fill this out, it goes to the bank for the security deposit? Mind you, my position would be "I'll send it to the bank directly," but I wonder whether the ruling deals with that possible loophole.

But even if the bank gets the SS number from the tenant directly, as posted recently-- http://www.tenant.net/.WWW/ubbgraphics/ultimatebb.php?ubb=get_topic;f=3;t=001136#00000 0, apparently some banks are giving landlords 1099s to distribute to their tenants. All they have to do is look at the 1099s.

This is serious business. You do NOT want your landlord to have your social security number, not just because of identity theft but because of tenant blacklists.

<small>[ April 24, 2005, 10:07 AM: Message edited by: Concourse ]</small>
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Aubergine » Sun Apr 24, 2005 10:20 am

Social Security death records are public -- that's why you can look up the SSNs of deceased persons online.

<small>[ April 24, 2005, 10:21 AM: Message edited by: aubergine ]</small>
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby HardKnocks » Sun Apr 24, 2005 11:07 am

I know I've asked this before, but don't they usually get your SSN when they do they initial credit check to decide whether or not to give you the apt.?
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Aubergine » Sun Apr 24, 2005 1:24 pm

Originally posted by Concourse:
Anna, that doesn't appear to be the full decision, as I noted that the judge's finding that the landlord was engaged in "deception" is not quoted in the text. Any chance you can post the remainder or provide a link to the text? thanx.
The decision is available for free as an official slip opinion (2005 NY Slip Op 25078) from the New York State Law Reporting Bureau:

http://www.nycourts.gov/reporter/3dseries/2005/2005_25078.htm

or from the West New York Slip Opinion Service:
http://nyslip.westgroup.com/search/default.wl?rs=NYSL2.0&vr=2.0&type=cite (enter 25078)

<small>[ April 24, 2005, 01:43 PM: Message edited by: aubergine ]</small>
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Cranky Tenant » Sun Apr 24, 2005 1:30 pm

Originally posted by Bleary-eyed tenant:
I know I've asked this before, but don't they usually get your SSN when they do they initial credit check to decide whether or not to give you the apt.?
Bleary, LLs have only been doing SSN based crdit checks for the past ten or fifteen years. Tenants who moved in prior to this practice were not required to provide their SSN Also, spouses of tenants who may have later been added to the lease, or family members who succeeded the primary tenant are not subject to credit checks.

LLs, Realtors and Management companies have the right to ask, and prospective tenants have the right to refuse. Problem is, refusing isn't going to get you the apartment if you're not already a tenant.
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Concourse » Sun Apr 24, 2005 2:20 pm

Aubergine--thanks for the link.

Another thing that strikes me as a little mysterious about this case is how it wound up in court in the first place. If I understand this correctly, the landlord sent her this form and the tenant goes ahead and sues.

Jeez Louise, wasn't that a little hasty? Yes, the landlord did threaten eviction. But all the tenant had to do was leave out the SS number and put the ball in the landlord's court. Was he really going to evict if she left out the SS number? Seems like a remote possibility at best. Seems like a waste of legal fees on the tenant's part, unless she can recoup them from the landlord-defendant.
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Cranky Tenant » Sun Apr 24, 2005 11:44 pm

Originally posted by Concourse:
Aubergine--thanks for the link.

Another thing that strikes me as a little mysterious about this case is how it wound up in court in the first place. If I understand this correctly, the landlord sent her this form and the tenant goes ahead and sues.

Jeez Louise, wasn't that a little hasty? Yes, the landlord did threaten eviction. But all the tenant had to do was leave out the SS number and put the ball in the landlord's court. Was he really going to evict if she left out the SS number? Seems like a remote possibility at best. Seems like a waste of legal fees on the tenant's part, unless she can recoup them from the landlord-defendant.
Anyone happen to notice the attorney for the Plaintiff was James Fishman? My guess is, there's a bit more to this story and, it's probably not the last we'll see from Mr. Fishman on tenants' privacy issues.

No, it's not what normally happens when a LL pulls this kind of crap but it's certainly is what should happen when a LL tries to bully tenants.

<small>[ April 25, 2005, 12:38 AM: Message edited by: Cranky Tenant ]</small>
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Concourse » Mon Apr 25, 2005 9:07 am

I couldn't disagree more strongly. If I hired a tenant lawyer and sued every time my landlord tried something dumb, I'd send the progeny of several tenant law firms through college. Much as I enjoy fattening the bank accounts of tenant lawyers, there are other ways of facing down landlords that don't involve that kind of expense.

In this case, there was an obvious solution that did not involve going to the NY State Supreme Court. I'm curious to know why that far less costly path wasn't taken.
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Re: Tenant Privacy And Landlords: Social Security Numbe

Postby Anna » Mon Apr 25, 2005 9:27 am

Decided on February 28, 2005
Supreme Court, New York County

Ariana Meyerson, Plaintiff,

against

Prime Realty Services, LLC, PRIME CROSSTOWN HOLDINGS, LLC, GREYSTAR-PRIME MANAGEMENT, Defendants.

118001/03

Diane A. Lebedeff, J.

This motion poses a question of nationwide first impression as to whether, as between two private citizens or entities and where no statute nor governmental regulation requires disclosure, a state consumer protection statute may be utilized to assert a claim that a social security number be protected from disclosure as confidential information. In the face of a motion to dismiss by entities which insist on their right to demand plaintiff's social security number, this question must be answered in favor of permitting the claim for protection to proceed.

Because the confidentiality of a social security number has been the subject of sharply different legal analyses, no single legal theory has emerged from prior judicial decisions considering this subject in various different fact patterns. For reasons explained below, in relation to a private transaction, this court may well adopt a bright line standard that a social security number is prima facie privileged information, with the privilege to be asserted only after the demanding party demonstrates entitlement to confidential information. While the privilege must give way as required by statute, regulation or court order, in ordinary circumstances, the person who holds the social security number appears to be free to decline disclosure.

This legal issue is posed by the straightforward facts present here. Petitioner's landlord and its agents have demanded that she reveal her social security number as she completes a form regarding the number of occupants of her apartment. A local law permits the landlord to inquire about apartment occupants, but does not authorize a demand for social security numbers (Administrative Code of the City of New York § 27-705 [c]). For reasons not relevant here, the landlord is not currently in possession of petitioner's social security number. Additional facts are added in the second section of this decision addressing the applicability of state consumer protection laws.

Plaintiff's complaint seeks declaratory relief (CPLR 3017 [b]), as well as injunctive and [*2]monetary relief under the New York consumer protection statute, General Business Law ("GBL") § 349 (h). The defendants' motion seeks dismissal of the complaint (CPLR 3211 [a][1], [7]). Both parties request an award of costs, sanctions and attorneys fees (22 NYCRR 130-1.1).

Plaintiff fears disclosure of her social security number ("SSN") may make her subject to identity theft, which has been a peril recognized for over a decade (Greidinger v. Davis, 988 F.2d 1344, 1354 [4th Cir. 1993], "an individual's concern over his SSN's confidentiality and misuse ... [is] compelling. For example, armed with one's SSN, an unscrupulous individual could obtain a person's welfare benefits or Social Security benefits, order new checks at a new address on that person's checking account, obtain credit cards, or even obtain the person's paycheck"). Misuse of a social security number can lead to identity theft, sometimes called "data rape" (Latasha D. McDade, Data Rape: Assault by an Unknown Predator The Supreme Court Went Wrong In TRW, Inc. v. Andrews, 45 S. Tex. L. Rev. 395, 396 [2005], reporting that one instance of identity theft occurs every seventy-nine seconds, stating such theft is particularly likely to be done by office workers who have access to a social security number in business records, and citing an instance of a victim left with bills from banks, credit card companies, and retailers in excess of one hundred thousand dollars). To give one striking example of the degree of sophistication now used by identity thieves: there is already a reported significant problem of such thieves seeking bankruptcy protection to forestall eviction or foreclosure to protect their ill-gotten property interests (Magdalena Reyes Bordeaux, Debtors in Pretension: In Light of the Growing Incidence of Identity Theft, Practitioners Need to Understand How to Expunge a Fraudulent Bankruptcy, 27-SEP L.A. Law. 24 [2004]).

Social Security Numbers: A Legal Background

Social security numbers were first adopted in 1936, when nine-digit account numbers were assigned to persons by the Secretary of Health and Human Services for the purpose of administering the Social Security laws (42 U.S.C. § 405 [c][2][B]). Federal law provides that social security account numbers and related records that are obtained or maintained by "authorized persons" shall be confidential, and no "authorized person" shall disclose any such social security account number or related record (42 U.S.C. § 405 [c][2][c][viii][I]).[FN1]

It is beyond doubt that governmental officials of every stripe may demand disclosure of a social security number, subject to certain restrictions. The primary limitation is contained in the federal 1974 Privacy Act, which requires that any agency requesting disclosure of a SSN must "inform that individual whether that disclosure is mandatory or voluntary, by what statutory authority such number is solicited, and what uses will be made of it" (5 U.S.C. § 552 [7] [*3][a][b][7]).[FN2] It is noteworthy that, even when government demands the information, a citizen may assert a claim that the government lacks sufficient need to justify seeking the private information (see, for example, Russell v. Board of Plumbing Examiners of County of Westchester, 74 F.Supp.2d 339 [S.D.NY 1999], rearg denied 74 F.Supp.2d 349, 45 Fed.R.Serv.3d 624 [S.D.NY 1999], affirmed 1 Fed.Appx. 38, 2001 WL 15628 [2d Cir. 2001], master plumber application requirements imposed by a county; see also, Dittman v. California, 191 F.3d 1020 [9th Cir. 1999], cert. denied, 530 U.S. 1261 [2000], state requirement acupuncturist provide social security number upon applying for license renewal). The Privacy Act does permit injunctive relief by individuals against the government, albeit there must be proof of some actual damages to achieve even nominal damages (Doe v. Chao, 540 U.S. 614 [2004], social security number revealed when plaintiff's Black Lung claim forms distributed).

There is a broad federal policy against the government revealing individuals' social security numbers. There are a variety of federal statutory restrictions on dissemination of such information, such as the federal Driver's Privacy Protection Act of 1994 (18 U.S.C. §§ 2721-2725; see Condon v. Reno, 528 U.S. 141, 151 [2000], act restricting states' ability to sell private data, which included social security numbers on driver license applications, was proper governmental exercise because it "regulates the States as the owners of data bases" being sold in interstate commerce).[FN3] Additionally, where there is a demand for disclosure of social security numbers under federal or state freedom of information laws, such numbers are universally held to be confidential (see Sherman v. U.S. Dept. of Army, 244 F.3d 357 [5th Cir. 2001], social security [*4]numbers are protected by concept of "informational privacy" and disclosure would be "unwarranted invasion of personal privacy" under 5 U.S.C. § 552 [b][7][C]; State ex rel. Beacon Journal Publishing Co. v. City of Akron, 70 Ohio St.3d 605, 640 N.E.2d 164 [1994], under state open records law social security numbers of public employees subject to employees' legitimate expectation of privacy and "a federal right to privacy ... protects against governmental disclosure of the private details of one's life").[FN4]

The foregoing authorities reflect a broad recognition of the confidential nature of a social security number. This result is not inconsistent generally with common law view of private information, described in U.S. Dept. of Justice v. Reporters Committee For Freedom of Press, 489 U.S. 749, 763-764 (1989), a case involving the confidentiality of individual criminal history records, as follows:

"To begin with, both the common law and the literal understandings of privacy encompass the individual's control of information concerning his or her person. In an organized society, there are few facts that are not at one time or another divulged to another. * * * * According to Webster's initial definition, information may be classified as 'private' if it is 'intended for or restricted to the use of a particular person or group or class of persons: not freely available to the public.'"

As the Supreme Court concluded, the fact that the information resides in a governmental or other scattered record does not automatically defeat a privacy claim.

The Supreme Court also addressed the privacy tort theories which have achieved recognition in many jurisdictions:

"[A right to control private information was first enunciated in] Warren & Brandeis, The Right to Privacy, 4 Harv.L.Rev. 193, 198 (1890-1891) ('The common law secures to each individual the right of determining, ordinarily, to [*5]what extent his thoughts, sentiments, and emotions shall be communicated to others .... [E]ven if he has chosen to give them expression, he generally retains the power to fix the limits of the publicity which shall be given them'). The common law recognized that one did not necessarily forfeit a privacy interest in matters made part of the public record, albeit the privacy interest was diminished and another who obtained the facts from the public record might be privileged to publish it. See * * * Restatement (Second) of Torts § 652D, pp. 385-386 (1977) ('[T]here is no liability for giving publicity to facts about the plaintiff's life that are matters of public record, such as the date of his birth .... On the other hand, if the record is one not open to public inspection, as in the case of income tax returns, it is not public and there is an invasion of privacy when it is made so'); W. Keeton, D. Dobbs, R. Keeton, & D. Owens, Prosser & Keeton on Law of Torts § 117, p. 859 (5th ed. 1984) ('[M]erely because [a fact] can be found in a public recor[d] does not mean that it should receive widespread publicity if it does not involve a matter of public concern')." (489 U.S. 764, fn 15.)[FN5]

It is also observed that New York generally follows the same principles set forth above. For instance, in relation to freedom of information requests, social security numbers are redacted (Beyah v. Goord, 309 AD2d 1049, 1052 [3d Dept. 2003], prisoner request for guards' social security numbers; Parker v. State of New York, 269 AD2d 255 [1st Dept. 2000], same; Bibeau v. Cantiague Figure Skating Club, Inc., 294 AD2d 525, [2d Dept. 2002], social security number to be redacted from plaintiff's proof of earnings tendered in discovery; Adler v. Jackson, 185 Misc 2d 45 [Sup. Ct. Queens Co. 2000], Department of Motor Vehicles could properly require disclosure of social security number on license application under Privacy Act provisions).

Concluding this broad review of the treatment of social security numbers, it is clear that the weight of authority favors treating a social security number as private and confidential information. In casting for a proper legal characterization, the law appears to support a [*6]conclusion that a social security number is protected by something akin to a privilege against disclosure, which privilege is to be asserted only after legal authority for the demand is demonstrated.

<small>[ April 25, 2005, 09:32 AM: Message edited by: Anna ]</small>
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