March 22, 2000
RE: Gramm_Leach_Bliley Act Privacy Rule, 16 CFR Part 313 _Comment
To Whom It May Concern,
I am writing on behalf of Investigative Information Services, Inc., regarding our concern with the proposed regulations to implement Title V of the Gramm_Leach_Bliley Act of 1999. As President of Investigative Information Services, Inc., as well as the Private Investigators Association of Florida, Inc., a statewide professional private investigator association, 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 is our 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 seems to be offering a distinction by describing financial information. We believe the Act provides opt_out of information regarding credit history, employment and financial assets. But name, address and telephone number should not be classified as "non_public."
Licensed private investigators play an vital role in civil and criminal justice systems which is not understood by many. Licensed private investigators support law enforcement units that are much of the time overwhelmed by violent criminal caseloads. Licensed private investigators are able to provide investigative services to victims of non-violent crimes. The information we obtain regarding addresses and telephone numbers is essential to our conduct of business and fulfilling our obligations to consumers. We utilize this information to investigate such crimes as identity theft, embezzlement, insurance fraud, locate delinquent debtors, delinquent child support debtors and serve process among other things.
If this information is deemed "non_public personal," only scam artists and criminals will benefit and the law_abiding consumer will be the loser. We urge you to define non_public personal information in the manner that Congress intended.
Deborah L. Sturgeon, FCI, CMI