FTC: Consumer Privacy Comments Concerning Strasburger & Price, L.L.P.--P974806 STRASBURGER & PRICE, L.L.P.
VIA TELEFAX: (202) 326-2396 Chairman RE: Support of Self-Regulation for Informational Data Bases Dear Mr. Chairman: In response to the Commission's request for additional comments following the June 10, 1997 hearings, I would offer the following: I am a Texas trial lawyer engaged in complex civil litigation, and am also a regular user of public and non-public records, data bases, credit headers, etc. I support the proposition of self-regulation. The data we regularly access and use in our work for 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. Frivolous lawsuits have become the bane of our existence. Con artists abound, and are difficult to uncover without collateral information sources of unimpeachable quality. The data base information that we access allows my clients to defend themselves, without looking to government for help. Further regulation of these data bases would create additional barriers, and would encourage fraud and misuse of our judicial processes. We feel ethically bound to keep the information that we gather confidential, and we strive to maintain a high degree of security and accuracy in our use of the reports generated through informational data bases. Of course, it would defeat the purpose of a collateral information data base if the subject of the investigation were allowed to "opt out" of the data base or otherwise receive notice of our inquiry. indeed, for those who choose to perpetrate fraud, control of information is their most effective weapon. We recognize the interest that the Commission may have in protecting the privacy of members of the public. Such protection of privacy can be managed through self-regulation regarding the use and distribution of data base material legally obtained. The investigative industry has stated a willingness and desire to self-regulate. Similarly, the legal community has long been subject to standards which control the dissemination of otherwise private and confidential information. Persons who appropriately use such informational data bases must have the opportunity to self- regulate, and would undoubtedly welcome the government’s help in enforcing appropriate standards to preserve privacy while still providing access to these important sources of information. I ask that you support self-regulation, and work with the investigative industry to successfully bring about policies and procedures that we can all live with in a free society. Respectfully submitted, JJ Juneau James J. Juneau JJJ/les |