FTC: Consumer Privacy Comments Confidential Advisory Services, Inc.--P974806 CONFIDENTIAL ADVISORY SERVICES, INC. July 15, 1997 Mr. Robert Pitofsky, Chairman, Federal Trade Commission Re: Support of Self Regulation Dear Mr. Chairman: In response to the Commission’s request for additional comments following the hearings held June 10, 1997, I as a licensed private investigator am a regular user of public and non-public records 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, the regulation would create additional barriers to use that today save lives, prevent fraud and bring families together. Much of my business focuses on prevention of fraud and response to fraud. Without access to this information, law abiding citizens have few means to protect themselves and/or build cases to pursue the perpetrators of fraud. The perpetrators often use multiple names and addresses that would be difficult to tie together without a free flow of information. In addition, when illegal activities are uncovered, there is a responsibility for any investigator to notify law enforcement authorities. When the information on illegal activities is turned over to law enforcement authorities, these authorities are appreciative of the information provided. 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. 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 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 in a free society. Respectfully submitted, Confidential Advisory Services, Inc. Joan T. NeuhausJoan T. Neuhaus President JTN/sp cc:Ken Bentsen, Congressman 87th Precinct 5615 MORNINGSIDE DRIVE · SUITE 304 · HOUSTON, TEXAS 77005 |