THISTLE INVESTIGATING SERVICES P.O. Box 434 August 22, 1997 Secretary, Federal Trade Commission RE: Self regulation U.S. Federal Trade Secretary: This is in response to the Commission's request for comments following the 6/10/97 hearing. As a licensed private investigator, I am a user of public and non-public records (such as credit headers) and I support the proposition of self regulation. The data we access and use in our reports to clients has a beneficial use and need in our society. It is important that a free flow of information be available to support commerce and our judicial system. It also allows the public, which does not have the resources to manage all the problems they are faced with, to defend itself without looking to government for help. Further regulation would create additional barriers for us that today save lives, prevent fraud and bring families together, as in such case as the "Confidential Intermediary". In Michigan, a court appointed "CI" can view closed records of adult adoptees in the state capital. Since most of these are old, incorrect addresses, a "credit header" may be helpful in obtaining a current address. We are required to keep the information confidential and maintain a high degree of accuracy in our reports due to established laws. To have the subjects of our investigations able to browse around in our inquiries and data or opt out of the data bases that are private and public would severely cripple our industry. Privacy protection can be managed via our industry's self regulation of uses and distribution. Our industry has stated its willingness and desire for self regulation. We welcome the government's help in enforcing rules through our industry's efforts. I respectfully request your support of self regulation, working with representatives of our industry to bring about policies and procedures that we can all live with. Respectfully yours, PAST PRESIDENT: MICHIGAN COUNCIL OF PRIVATE INVESTIGATORS |