COMMENTS OF INFORMATION INDUSTRY ASSOCIATION CONCERNING CONSUMER ON-LINE PRIVACY-P954807
INFORMATION INDUSTRY ASSOCIATION
DATE: April 15, 1997
TO: Donald S. Clark / Federal Trade Commission
FROM: Alden Schacher/IIA
RE: Data Base Workshop --Request to Participate, P974806 & Consumer Privacy l997--Request to Participate, P954807
Attached, please find the original plus six copies of the Information Industry Association's request to participate in the Commission's June 10 - 12 Database and Consumer Privacy Workshops.
Should you have any questions, please do not hesitate to contact me. My direct number is (202) 319-0141.
INFORMATION INDUSTRY ASSOCIATION
April 15, 1997
Mr. Donald S. Clark, Secretary
Dear Mr. Clark:
On behalf of the Information Industry Association, I am writing to request that the Association be represented during the Federal Trade Commission's June 10- 12 Database and Consumer Privacy workshops. I am requesting that IIA be represented through designee[s] to be named at a later date who can provide expertise with regard to several of the topics the Commission has identified for review. We will also submit, for the record, substantive written comments.
IIA is the foremost trade association of companies involved in the creation and distribution of information products and services, particularly in the electronic environment. IIA's 550 member companies include leading publishing firms, the nation's most innovative software producers and the world's largest providers of telecommunications services and technologies. IIA's membership is reflective of the entire information industry and includes not only large multinationals but many entrepreneurial start-ups.
Without the information-rich content provided by our members, many of the important societal and economic benefits enjoyed by consumers today-- and being developed for tomorrow-- simply would not exist. In creating and marketing these products and services, virtually every IIA member company collects or uses personally identifiable data in some way. Thus, the Association and our members have much to contribute to the June workshops, and have a vital stake in the outcome of the FTC's actions with regard to both the database and consumer privacy studies.
Specifically, IIA has among our membership several companies which are encompassed within the FTC's scope for the Database workshop and the look-up service study. The FTC has requested that participants be able to represent the perspective of database operators; suppliers of data to databases and other expert opinions with regard to the definition, operation and uses of commercial "look-up" services. [See sections 1.11.35] IIA can identify designee[s] to address issues raised generally by the study and by these sections.
With regard to the Consumer Privacy workshop, IIA participated in last year's workshop and submitted substantive written comments. The Association has among its membership online service providers, Web site owners, online marketers and interactive technology developers--all identified by the FTC as interests that should be represented. Generally, IIA could provide designee[s] to address issues raised by sections 2.1, 2.3, 2.7, 2.9, and 2.15.
I appreciate your consideration of this request and look forward to working with the Commission on the upcoming workshops. Should you have any questions or require more information, please do not hesitate to contact me or Ms. Alden Schacher of IIA's government relations staff.
Ronald G. Dunn
cc: David Medine, Associate Director Credit Practices
1625 Massachusetts Avenue, NW Suite 700 Washington, DC 20036 202-986-0280 FAX 202-638-4403