FTC: Consumer Privacy Comments Concerning Superior Service Bureau--P974806

SSB
Superior Service Bureau
Superior Group, Inc.

6/25/97

Investigative Services

Secretary, Federal Trade Commission
Room H-159
Sixth and Pennsylvania Avenue, NW
Washington. DC 20580

RE: Support of Self Regulation

Dear Mr. Secretary,

In response to the Commissions' request for additional comments following the hearing held June 10, 1997, I, Greg Fairbanks, a licensed private investigator, am a regular user of public and non-public records (such as credit headers), and support the proposition of self regulation

The data that we regularly access and 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 to us that today save lives, prevent fraud and bring families together.

We are required to keep the information confidential and maintain a high degree of accuracy in our reports due to law and the test of the courts and market place. To have the targets of our investigations able to browse around in our inquiries and data or opt out of databases that are private and public would be the death of our industry and freedom. The prevention of wrong doing and protection of fraud are real tests of the use of data.

Privacy protection can be managed through our industries' self regulation of uses and distribution. Our industry had stated a willingness and desire to self regulate. We welcome the government's help in enforcing the rules, through our efforts and the industries' associations.

I ask that you support self regulation and work with the industry to successfully bring about policies and procedures that we can all live with in a free society.

Greg Fairbanks

Gregory E. Fairbanks
President

GEF/sw