FTC: Consumer Privacy Comments Concerning Pacific Investigations--P974806

PACIFIC
I N V E S T I G A T I O N S

June 30, 1997

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 Commission's request for additional comments following the hearing held on June 10, 1997, I, as a licensed private investigator, am a regular user of public and non-public records (such as credit headers), and I support the proposition of self regulation.

The data that we regularly access and use -in our reports to clients has a beneficial use and a need in our society. It is important dud a free flow of information be available to support commerce and our judicial system. It also allows the public, who do 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 saves lives, prevents fraud and brings families together.

We are required to keep the information confidential and maintain a high degree of accuracy in our reports due to law, 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 the databases that are private and public, would be the death of our industry and freedom. The prevention of wring doing and protection of fraud am real tests of the use of data. Privacy protection can be managed through our industry's self regulation, uses and distribution. Our industry had stated a willingness and desire to self regulate.

This industry must have the opportunity to self regulate and welcomes the government's help in enforcing the rules through the industry's efforts.

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.

Sincerely,

PACIFIC INVESTIGATIONS

Richard A. Crooks

Richard A Crooks, CPP, CPI, CFE
RAC:br

1207 Carlsbad Village Drive H-2, Carlsbad, California 92008-1958 · (760) 434-2600 · Fax (760) 434-2687
California License Number PI 9907