FTC: Consumer Privacy Comments Concerning Carl S. Raphael, P.I.--P974806 CARL S. RAPHAEL, PI NC
PI #2022 June 19, 1997 Secretary, Federal Trade Commission RE Support of Self Regulation Dear Mr. Secretary: In response to the Commissions request for additional comments following the hearing held June 10, 1997, I am compelled to write to you on this matter. I am a licensed Private investigators both in North Carolina and Florida. I pay my business and liability insurance, cannot operate without it, and submit freely to the licensing boards of North Carolina and Florida, who have enacted many laws to control our industry. I am professional in my demeanor and operations, and look forward to continued operations far into the future. The Private Investigator in the United States, joined by a worldwide network of Investigators in every free country, is a vital part of law enforcement, as you must be aware. No, we do not put bank robbers and murderers in jail, but we are the LAW ENFORCEMENT OF CIVIL LAW. Our job is just as important, although perhaps not as glamorous as the police officer, with his gun and badge. And while our techniques are various and not nearly as defined as that of the police, our efforts and results are just as important. Without civil law, civil attorneys, and the investigators who would right civil wrongs against persons and property? Laws and civil recourse for fraud, negligence, personal and corporate liability, and the myriad of other areas of necessity for civil law is what ensures the Country will remain great. It is vital that the civil law tree of civil law and courts, civil law attorneys, and the Private Investigator remain intact, just as the criminal law tree of criminal law and courts, district attorneys, and the police remain intact. Surely you see this. In the tools of our trade, we use different tools than the criminal Investigator, but ones just as important. The data that we regularly access and use in our reports to our clients has a beneficial use and need in society. It is vital that a free flow of information be available to support commerce and Our civil judicial system. It is vital that we be allowed to continue our efforts to save lives, prevent fraud and bring families together. By us continuing our work, we can ensure that the general public has a path to take and a way to turn to ensure Civil law enforcement. We are the tools to ensure civil law will continue to rule. We are regulated now, in most areas, and the vast majority of Private Investigators are legitimate. We are required to keep our reports and information confidential, just as attorneys and their clients. We respect and follow this rule in all respects. It Is the backbone of our industry. To have the subjects of our investigations able to browse around in our inquiries and data, or opt out of the databases that are vital to our efforts, would be the death of our industry and the birth of a civil law nightmare that would have far-reaching effects. The prevention of fraud, conversion, child support withholding, and other vital needs in our society are the real tests of our use of the data we must have. We must continue to have access to the information we need, for the economic health of society. This includes access to Social Security number data, such as in Credit Headers. Privacy protection can be managed through our industries' self regulation and the existing, working, system of State regulation. Our industry had stated a willingness and desire to self regulate. We must be given the opportunity to self regulate and we welcome the government's help in enforcing the rules through the industry's efforts. I respectfully ask that you support self-regulation and work with the Investigative industry to successfully bring about policies and procedures that we can all live with in a free society. Sincerely, Carl S. RaphaelCarl S. Raphael, PI CSR/pc |