FTC: Consumer Privacy Comments Concerning Professional Investigators and Security Association--P974806

Professional Investigators and Security Association
POST OFFICE BOX 1836
VIENNA, VIRGINIA 22180

July 3, 1997

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

RE: Support of Self Regulation

Dear Mr. Secretary:

In response to the request of the Commission for additional comments following the hearings held on June 10, 1997, I as a duly licensed and registered private investigator/security/or allied entity 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 legitimate business purposes within our judicial system. It also allows the general public, with few resources to manage all of the problems generally dealt with, to defend itself without looking to the federal government for assistance. Further, regulation would undoubtedly create additional barriers to us that today save lives, prevent fraud and bring families together.

We in our industry are required to keep the information in a confidential manner and maintain a high degree of accuracy in our reports due to the law, tests of the courts and the market place. To have the targets of our investigations free to browse in our inquiries and data or opt out of databases that are private and public would be the death of our industry and be detrimental to our clientele. The prevention of wrongdoing and protection against fraud and deceit are real tests of the use of meaningful data.

Privacy protection can be managed through industry regulation of uses and distribution, and professionals have stated a desire and willingness to self regulate. I ask that you support our self regulation and work with the industry to successfully bring about policies and procedures that we can all live with in a free and open society.

Sincerely,

PROFESSIONAL INVESTIGATORS and
SECURITY ASSOCIATION, INC.

Donald L. Koch

Donald L. Koch
President Donald L. Koch
e-mail: mcipd@aol.com President