[jheitmann]

I haven't had to deal with PII issues for a few years now so I might be a bit rusty but: Regardless of how driver's license ids are created, they are global identifiers of a specific person. If company A knows a person's driver's license number, and company B knows that same person's driver's license number, the two companies can be certain they're talking about the same person.

That those ids are often formed from a transparent function of other PII only makes the issue more extreme. It's like PII^2.