FTC: Consumer Privacy Comments Gradoni & Associates--P974806

Gradoni &                                                                      Professional Investigative Services
Associates                                                                                           State License A5741

July 14, 1997

Chairman, Federal Trade Commission                                                  Via Facsimile
Room H-159
Sixth & Pennsylvania Avenue N.W.
Washington, D.C. 20580

RE: Support of Self Regulation

Dear Mr. Chairman:

In response to the Commission's request for additional comments following hearings held June 10, 1997, I (or your customer/client) as a licensed (private investigator/security/lawyer/insurance company) 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 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 of 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.

Private protection can be managed through our industry’s self-regulation of uses and distribution. Our industry has 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 our efforts and the industry's associations.

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 a free society.

Respectfully Submitted,

GRADONI & ASSOCIATES

JJ Gradoni

J.J. Gradoni

14620 Wunderlich, Suite 120    ·     Houston, Texas 77069    ·     (281) 440-0800    ·    Fax (281) 440-0208