COMMENTS OF INTERACTIVE SERVICES ASSOCIATION CONCERNING CONSUMER ON-LINE PRIVACY-P954807 INTERACTIVE April 15, 1997 Secretary RE: Consumer Privacy 1997 - Comment P954807 The Interactive Services Association (ISA) requests to participate in "Session Two: Consumer Online Privacy" during your Public Workshop on Consumer Information Privacy scheduled for June 10, 1997. The ISA is the leading trade association representing companies devoted exclusively to promoting and developing consumer online interactive services worldwide. ISA has over 350 member companies in the fields of Internet and online services, interactive telephone television, screen telephone, online financial services, and interactive marketing and communications. The ISA membership includes many of the leading firms in these areas including such innovative companies as America Online, AT&T, Bell Atlantic, CompuServe, IBM, Microsoft, NETCOM, Netscape and Prodigy. Our industry proactively responds to the needs of our customers as they relate to online privacy concerns. THE INTERACTIVE SERVICES ASSOCIATION The ISA is uniquely suited to participate in Session Two: Consumer Online Privacy because its members, the inner circle of the Internet and online community are also joined with World Wide Web-based marketers to form the foundation of this exploding new medium. The Internet and online consumer is offered the opportunity to join virtual communities, send and receive email, maintain accounts, design web pages, conduct commerce, access and view some of the most innovative content online and explore the vast network of resources on the Internet. At the same time, the industry believes it is the responsibility of the individual companies to ensure their customers are made aware of the information being collected, how it is being used and what to do if they do not want to receive unsolicited mailings. The ISA industry has developed a set of privacy guidelines for use by its member companies and their customers. The ISA presentation in Session Two will describe these guidelines and discuss other activities by the ISA and its member companies in the areas of online privacy and online consumer education. THE INTERACTIVE SERVICES ASSOCIATION'S PROJECT OPEN The Interactive Services Association, in partnership with America Online, AT&T, CompuServe, Microsoft and NETCOM On-Line Communication Services, requests the opportunity to participate in the Federal Trade Commission Public Workshop on Consumer Information Privacy, Session Two: Consumer Online Privacy. As noted in the companion letter from the ISA, industry self-regulation and technological advances can go far in promoting online privacy. Still, it is our belief that a well rounded approach to online privacy incorporates information that empowers consumers to make choices about their privacy interests. In response to questions 2.10 and 2.13, the coalition would like to discuss its activities promoting consumer education on online privacy, specifically through sponsorship and participation in Project OPEN, the Online Public Education Network. In the year since the launch of Project OPEN, the sponsors have enjoyed the opportunity to meet and correspond with literally hundreds of consumers. Through these interactions, we have learned that consumers are seeking high-quality, reliable basic information about online and Internet privacy. As technology industry professionals, the Project OPEN sponsors are uniquely qualified to help fill that need. The sponsors of Project OPEN have taken the lead in teaching consumers about online privacy issues. Project OPEN's brochure, How to Get the Most Out of Going Online, provides an introduction to online privacy issues and offers useful tips for people venturing online for the first time. The brochure introduces parents to software tools that can be easily programmed to restrict the information that a child can divulge to others online, whether in a chat room or thorough e-mail. The software can also assist parents who want to limit the information that a marketer can collect from a child through an online survey or registration process. In the spring of 1997 Project OPEN sponsors will launch Protecting Your Privacy When You Go Online, a publication providing detailed information about online privacy issues, ranging from what people can learn about your identity in a chat room to personal online safety, data collection, e-mail and "cookies." The publication explains online privacy in an easy-to-understand format and provides "Quick Tips for Protecting Your Privacy." The attached comments provide more detail about the accomplishments of the Project OPEN sponsors in promoting online consumer education, through workshops, public appearances, Web site postings, and brochure distribution. The ISA and Project OPEN sponsors are committed to helping consumers understand the issues surrounding online and Internet privacy. In concert with industry self-regulation and technological developments such as the Platform for Privacy Preferences, we believe that consumers can be empowered to make informed choices about their privacy, so that they can travel in the online world safely and responsibly The ISA remains committed to working the variety of interested groups on these issues as the Internet and its technology continues to evolve and we appreciate the opportunity to participate at your Public Workshop. Please feel free to contact either me or Brian O'Shaughnessy at 301-495-4955 to discuss further details about this submission. Very truly yours, Jeff B. Richards Jeff B. Richards CONSUMER PRIVACY 1997 - COMMENT
P954807 The Interactive Services Association and the Project OPEN sponsoring companies thank the Federal Trade Commission for this opportunity to provide comments on online/Internet privacy and to report on industry efforts to help educate consumers about how to protect their privacy when they go online. These comments are offered in combined response to question 2.10, regarding individual steps to address online privacy issues, and 2.13, regarding privacy concerns that are not adequately addressed by existing guidelines. Project OPEN, the Online Public Education Network, is a partnership of the Interactive Services Association, the National Consumers League and the leading online and Internet access companies -- America Online, AT&T, CompuServe, Microsoft and NETCOM On-Line Communication Services. Launched in March 1996, Project OPEN conducts education and outreach on key issues facing the growing world of Internet and online service users. The organization places particular emphasis on online privacy, parental empowerment and child safety, intellectual property rights and consumer protection. Consumer Education and Online Privacy The online world presents tremendous resources for consumers, such as access to literature, news, games and shopping, as well as the opportunity to share ideas, exchange e-mail, and make new friends. Because these resources can be accessed in the privacy of one's home or office, it is often hard for consumers to distinguish whether the Internet is truly private, like a living room or public, like a shopping mall. According to a recent survey by the Boston Consulting group, people are 40% to 50% more likely to engage in online transactions and share their personal information if they know who is collecting the data and how it will be used. Industry guidelines that can delineate responsible practices for Web site operators are certainly part of the equation. In the thirteen months since Project OPEN's launch, its sponsors have enjoyed the opportunity to meet and correspond with literally hundreds of consumers through public appearances, workshops, e-mail messages, letters and phone calls. Through these interactions, we have learned that consumers are seeking high-quality, reliable, basic information about online and Internet privacy issues. Consumers want to know if they remain anonymous when they go online and if not, who can see them. How vulnerable is their private information? Are chat rooms public or private? When they post a message to a bulletin board, where does it go next? Is anyone else reading their e-mail? Are their movements online traceable? How do marketers learn their e-mail addresses? Are online purchases secure? Through media and from their friends, consumers hear about incidents of privacy invasion and online abuse and wonder about whether they should be concerned. The Project OPEN sponsors provide the information and resources that help consumers understand Internet and online privacy, so that they can to travel in the online world safety and responsibly. The sponsors of Project OPEN have taken the lead in teaching consumers about online privacy issues. Project OPEN's first brochure, How to Get the Most Out of Going Online, provides an introduction to online privacy issues and offers useful tips for people venturing online for the first time. The brochure introduces parents to software tools that can be easily programmed to restrict the information that a child can divulge to others online, whether in a chat room or thorough e-mail. The software can also assist parents who want to limit the information that a marketer can collect from a child through an online survey or registration process. How to Get the Most Out of Going Online has been featured in national publications such as USA Today, The Christian Science Monitor, Family Circle, Essence and Moneysworth. The publication is available at no charge through a toll-free hotline number. Over 125,000 copies of the brochure have been distributed to teachers, computer trainers, church groups and families. Many have requested bulk orders for distribution to students in their classrooms and computer labs. The brochure is posted along with additional privacy information on the Project OPEN Web site (http://www.isa.net/project-open). More than 70 Web sites have linked to the Project OPEN consumer education information. As technology industry professionals, the Project OPEN sponsors are uniquely qualified to bring accurate, reliable information to consumers who want to know more about online privacy. In the spring of 1997, Project OPEN sponsors, joined by NYNEX, prepared Protecting Your Privacy When You Go Online, a brochure providing detailed information about online privacy issues, ranging from what people can team about your identity in a chat room to personal online safety, data collection, e-mail and "cookies." The publication explains online privacy in an easy-to-understand format and provides the following "Quick Tips for Protecting Your Privacy"
Equipped with the newly published educational materials, Project OPEN will continue to its aggressive promotion of online safety. In April, representatives will host an exhibit at the National Consumers League Annual Conference in Philadelphia to inform consumers about privacy issues and software tools that allow marketers to track online usage. A Project OPEN sponsor will meet with members of the National School Boards Association's Institute for the Transfer of Technology to Education, in conjunction with the associations annual meeting. Workshops and training materials on privacy issues suitable for teachers and computer trainers are also under development. Project OPEN is working with representatives from leading educational associations to develop materials to acquaint teachers with the online and Internet medium. Some 40,000 brochures have been distributed to members of the National Education Association, the National Association of Secondary School Principals, the National Association of Elementary School Principals, the American Association of School Administrators and the National School Boards Association. In addition, AT&T includes Project OPEN brochures in information kits distributed to nearly 20,000 Learning Network partners. While partnership with these organizations has assisted in getting the message out to consumers, it has also provided us with a valuable source of information and feedback about the privacy concerns of the average computer user. Beyond brochure distribution, the Project OPEN sponsors and partners have been active in promoting online privacy safeguards to policy makers and association professionals. In July 1996, Project OPEN and the ISA sponsored "Settling the Virtual Wild West: Empowering Consumers to Make Smart Choices" -- a roundtable discussion held in conjunction with the ISA's annual conference. Featured speakers included Jodi Bernstein, Director of the Federal Trade Commissions Bureau of Consumer Protection; Linda Golodner of the National Consumers League; and 1996 Project OPEN Chairman Bill Burrington. Project OPEN sponsors have participated in briefings for congressional staff on such issues as indecency and parental control technologies, intellectual property and education and technology. 1997 Project OPEN Chairman Irene Hashfield of AT&T participated in a children's privacy workshop at Union College in New Jersey, sponsored by Rep. Bob Franks (R-NJ). In October 1996, Project OPEN worked with the U.S. Office of Consumer Affairs to organize a roundtable on online consumer issues, including privacy, as part of the events surrounding National Consumers Week. The discussion included Leslie L. Byrne, director of the U.S. Office of Consumer Affairs; Susan Grant, director of the National Fraud Information Center; Bill Burrington, director of law and public policy for America Online; Glee Harrah Cady, manager of public policy for NETCOM On-Line Communication Services; Joan Huber from AT&T; and former Project OPEN Director Sara Fitzgerald. In March 1997, project OPEN Manager Nancy Publicover participated in a workshop sponsored by the Children's Defense Fund. This workshop was designed to brief child safety advocates about issues of online privacy. The Project OPEN companies are able to share their expertise in interactive technology to help consumers better understand and enjoy the online and Internet world. At the same time, the Project OPEN sponsors and partners recognize that they are uniquely situated to bring consumer concerns to the attention of the industry. Many interactive companies are small start-ups, uninitiated in consumer issues and focused on meeting their bottom line. They are simply unaware that, especially for a novice user, the Internet and online world is new and uncharted. At the ISA Annual Conference in Washington, DC in July 1997, Project OPEN members are helping to organize a plenary session on online privacy and other consumer issues, to communicate the concerns of consumers to the industry leaders in attendance. At such industry events and through industry publications, the sponsors and partners communicate the importance of consumer education, promote practices and policies that respond to consumer concerns and so promote the long-term growth of the industry. Summary Project OPEN looks forward to continuing its work with consumers to help them protect their privacy when they go online and to empower them to make informed choices about the personal information they share. Through brochures, training workshops, speaking engagements and public service announcements, Project OPEN will continue to work with other groups to develop and publicize appropriate industry practices. The Project OPEN sponsors and partners thank the FTC for the opportunity to contribute to the discussion on these important issues facing our industry. We also commend the agency for its leadership in organizing this forum to help us educate consumers and our industry colleagues about the important choices they face when it comes to protecting privacy. Consumer Education Industry self-regulation and technological advances can go far in promoting online privacy. Still, it is our belief that a well rounded approach to online privacy incorporates information that empowers consumers to make choices about their privacy interests. Under the auspices of the ISA, Project OPEN, the Online Public Education Network, conducts education and outreach on privacy and other key issues facing the growing world of Internet and online service users. Project OPEN is sponsored by the leading online and Internet companies -- America Online, AT&T, CompuServe, Microsoft and NETCOM On-Line Communication Services. In the year since the launch of Project OPEN, the sponsors have enjoyed the opportunity to meet and correspond with literally hundreds of consumers. Through these interactions, we have learned that consumers are seeking high-quality, reliable basic information about online and Internet privacy. As technology industry professionals, the Project OPEN sponsors are uniquely qualified to help fill that need. The sponsors of Project OPEN have taken the lead in teaching consumers about online privacy issues. Project OPEN's brochure, How to Get the Most Out of Going Online, provides an introduction to online privacy issues and offers useful tips for people venturing online for the first time. The brochure introduces parents to software tools that can be easily programmed to restrict the information that a child can divulge to others online, whether in a chat room or thorough e-mail. The software can also assist parents who want to limit the information that a marketer can collect from a child through an online survey or registration process. The Project OPEN brochure has been featured in national publications such as USA Today, The Christian Science Monitor, Family Circle, Essence and Moneysworth. The publication is available at no charge through a toll-free hotline number. Over 100,000 copies of the brochure have been distributed to teachers, computer trainers, church groups and families. Many have requested bulk orders for distribution to students in their classrooms and computer labs. In addition, the brochure is posted along with additional privacy information at the Project OPEN Web site (http://www.isa.net/project-open). More than 70 Web sites have linked to the Project OPEN consumer education information. As technology industry professionals, the Project OPEN sponsors are uniquely qualified to bring accurate, reliable information to consumers who want to know more about online privacy. In the spring of 1997, Project OPEN sponsors prepared Protecting Your Privacy When You Go Online, a publication providing detailed information about online privacy issues, ranging from what people can learn about your identity in a chat room to personal online safety, data collection, e-mail and "cookies." The publication explains online privacy in an easy-to-understand format and provides the following "Quick Tips for Protecting Your Privacy"
Equipped with the newly published educational materials, Project OPEN will continue to its aggressive promotion of online safety. In April, representatives will host an exhibit at the National Consumers League Annual Conference in Philadelphia to teach consumers about "cookies," software tools that allow marketers to track online usage. A Project OPEN representative will attend an April reception for the National School Boards Association Institute for the Transfer of Technology to Education to discuss consumer online issues with technology oriented teachers. Workshops and training materials on privacy issues suitable for teachers and computer trainers are also under development. And at a May conference appearance, a Project OPEN representative will provide a consumer's perspective on online privacy to a gathering of public relations executives. Project OPEN is working with representatives from leading educational associations to develop materials to acquaint teachers with the online and Internet medium. Some 40,000 copies of How to Get the Most Out of Going Online have been distributed to members of the National Education Association, the National Association of Secondary School Principals, the National Association of Elementary School Principals, the American Association of School Administrators and the National School Boards Association. In addition, AT&T includes Project OPEN materials in information kits distributed to nearly 20,000 Learning Network partners. While partnership with these organizations has assisted in getting the message out to consumers, it has also provided us with a valuable source of information and feedback about the privacy concerns of the average computer user. Beyond brochure distribution, the Project OPEN sponsors and partners have been active in promoting online privacy safeguards to policy makers and association professionals. In July 1996, Project OPEN and the ISA sponsored "Settling the Virtual Wild West: Empowering Consumers to Make Smart Choices" -- a roundtable discussion held in conjunction with the ISA's annual conference. Featured speakers included Jodi Bernstein, Director of the Federal Trade Commission's Bureau of Consumer Protection; Linda Golodner of the National Consumers League; and 1996 Project OPEN Chairman Bill Burrington. 1997 Project OPEN Chairman Irene Hashfield of AT&T participated in a children's privacy workshop at Union College in New Jersey, sponsored by Rep. Bob Franks (RNJ). Project OPEN members have participated in briefings for congressional staff on such issues as indecency and parental control technologies, intellectual property and education and technology. In October 1996, Project OPEN worked with the U.S. Office of Consumer Affairs to organize a roundtable on online consumer issues, including privacy, as part of the events surrounding National Consumers Week. The discussion included Leslie L. Byrne, director of the U.S. Office of Consumer Affairs; Susan Grant, director of the National Fraud Information Center; Bill Burrington, director of law and public policy for America Online; Glee Harrah Cady, manager of public policy for NETCOM On-Line Communication Services; Joan Huber from AT&T; and former Project OPEN Director Sara Fitzgerald. In March 1997, Project OPEN Manager Nancy Publicover participated in a workshop sponsored by the Children's Defense Fund. This workshop was designed to brief child safety advocates about issues of online privacy. The Project OPEN companies are able to share their expertise in interactive technology to help consumers better understand and enjoy the online and Internet world. At the same time, the Project OPEN sponsors and partners recognize that they are uniquely situated to bring consumer concerns to the attention of the industry. Many interactive companies are small start-ups, uninitiated in consumer issues and focused on meeting their bottom line. They are simply unaware that, especially for a novice user, the Internet and online world is new and uncharted. At the ISA Annual Conference in Washington, DC in July 1997, Project OPEN will participate in a plenary session on online privacy, to communicate the concerns of consumers to the industry leaders in attendance. At such industry events and through industry publications, the sponsors and partners communicate the importance of consumer education, promote practices and policies that respond to consumer concerns and so promote the long-term growth of the industry. The ISA and Project OPEN sponsors are committed to helping consumers understand the issues surrounding online and Internet privacy. In concert with industry self-regulation and technological developments such as the Platform for Privacy Preferences, we believe that consumers can be empowered to make informed choices about their privacy, so that they can travel in the online world safely and responsibly. |