FTC: Consumer Privacy Comments Concerning Investigative Services, Inc.--P974806 INVESTIGATIVE P.O. Box 45143 Date: July 7, 97 TO: Mr. Robert Pitofsky FROM: Robert A. Dudash, CFE, CII REFERENCE: Support of Self Regulation Dear Mr. Chairman, In response to the Commission's request for additional comments following the hearing held June 10, 97, I as 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 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 use 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 marketplace. To have the targets of our investigations able to browse around in our inquiries and data, or opt out to databases that are private and public would be the death of our industry and freedom. The prevention of wrongdoing and protection of fraud are real tests of the use of data. Privacy protection can be managed through our industry's self-regulation of uses and distribution. Our industry has stated a willingness and desire to self regulation. This industry must have the opportunity to self regulate and welcomes the government's help in enforcing the rules, through our efforts and the industry's associates. 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. Respectfully submitted, Robert A. DudashROBERT A. DUDASH, CFE, CII |