Sent: Friday, March 10, 2000 11:26 PM
RE: Gramm-Leach-Bliley Act Privacy Rule,
16 CFR Part 313 -CommentTo Whom It May Concern:
I am writing to express my concern with the proposed regulations to
implement Title V of the Gramm-Leach-Bliley Act of 1999. As a licensed private
investigator and small business person, I fear we would lose a valuable and very necessary
source of locating witnesses and suspects if "non-public personal information"
is defined to include simple names and addresses of customers of financial institutions.
It was my impression that the clear intent of Congress was to provide
an opportunity for customers of financial institutions to "opt-out" of
sharing their personal financial information with non-affiliates of the
institutions. The statute provides protection for financial information--not mere names
and addresses. If all information available to a financial institution is defined as
"non-public personal information," then what is "public"? Congress
seemed to be offering a distinction by describing financial information. I believe the Act
provides opt-out of information regarding credit history, employment and financial assets.
But name, address and phone number should not be classified as "non-public."
Private investigators play an important role in our civil and criminal justice systems
which is not understood by many. The information we
obtain regarding addresses and phone numbers is essential to our conduct of business and
fulfilling our obligations to consumers. We utilize this
information to investigate embezzlement, insurance fraud, locate delinquent child support
debtors and serve process among other things. Stalkers and scam artists seldom reside
where their vehicles are registered so current address information is essential and law
enforcement seldom has the manpower to develop these cases for prosecution.
If this information is deemed "non-public personal," only wrongdoers and
criminals will benefit and the law-abiding consumer will be the loser. I urge you to
define non-public personal information in the manner that Congress intended.
Yours truly,
Steve Black
Diversified Investigative Group, Inc.
P.O. Box 44036
Oklahoma City, OK 73144
Phone: (405) 812-7168
Pager: (405) 980-2344
Fax: (419) 831-4944
Email: atakblak@home.com |