FTC: Consumer Privacy Comments Concerning Trace Investigations--P974806

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

Re: Support of Self Regulation

Dear Mr. Secretary:

In response to the Commission’s request for additional comments following the hearing held June 10, 1997, please note that I am in support of self regulation in the information services industries. As a licensed private investigator, I am a regular user of public and non-public records (such as credit headers), and am aware of the value of this information, when used for legitimate purposes.

The data that we regularly access and use in our reports to clients has a beneficial use and need in society. The free flow of such information supports commerce and benefits our judicial system. Furthermore, the free flow of information enables the public to protect itself against civil abuses and criminal wrongs. Excessive regulation and additional barriers to access of information would alarm a public already skeptical of government involvement in the minutiae of their lives.

Legal investigators are by various state and municipal laws required to keep confidential the information they gather, and to further insure the accuracy of that information when reporting to clients, who are usually attorneys and corporate officers. Market forces within our industry dictate attention and compliance to these safeguards. By and large, the data we gather is used to fight fraud and theft, to locate tortfeasors and "deadbeat" parents, and to provide information to the litigants in various civil and criminal actions around the country. It would be anathema to the interest of justice to have the "target" of an investigation routinely informed that information was being exchanged about him, or her.

Privacy protection can be managed through our industries’ willingness and ability to self regulate the uses and distribution of information. Many of us have routinely for years provided these safeguards to our clients and the public at large. We respectfully request to have the opportunity to formalize these efforts at self regulation, and to have the government’s support and assistance to that end.

I urge you to support our efforts to bring about policies and procedures which will protect the public, and at the same time ensure the flow of information essential to a free society.

Very truly yours,

Don C. Johnson

Don C. Johnson, CLI
Certified Legal Investigator
President, Trace Investigations
Vice President, Indiana Association of Private Detectives, Inc.