| HENDERSON & ASSOCIATES
INVESTIGATION, INC. P.O. BOX 51503 LIVONIA, MI 48151 (313) 261-5933 FAX (313) 421-2581 Secretary, Federal Trade
Commission Dear Federal Trade Secretary, In response to the State of Michigan and the State of Ohio request for additional comments following the hearing held June 10, 1997, I, as a licensed private investigator, am a regular user of public and nonpublic records (such as credit headers), and I support the proposition of self regulation. The data that we access daily and the use in our reports to clients has a beneficial use and need in society. It is important that a free flow of information be available to support commerce and our judicial system. It also allows the public, who does not have the resources to manage all of the problems they are faced with, to defend itself without looking to government for help. Further regulation would create additional barriers for us that today prevent fraud and bring families together, in as such the case as the "Confidential Intermediary". In Michigan, a court appointed Confidential Intermediary can view closed records of "Adult Adoptee" in Lansing, Michigan. In many cases, the information may not current, such as an address. By using a "credit header", a current address may be obtained. Witnesses in court cases are often located using the "credit header". We are required to keep the information confidential and maintain a high degree of accuracy in our reports due to laws. To have the targets of our investigation able to browse around in our inquires and data, or to opt out of the databases that are private and public would severely cripple our industry and freedom. Privacy protection can be managed through our industries self regulation of uses and distribution. Our industry has stated a willingness and desire to self regulate. CIVIL, CRIMINAL, INSURANCE INVESTIGATIONS LICENSED - BONDED This industry must have the opportunity to self regulate and welcomes the govemment's help in enforcing the rules through the industries efforts. I ask that you support self regulation and work with the industry to successfully bring about policies and procedures that we call all live with in a free society. Respectfully Submitted, |