FTC: Consumer Privacy Comments Concerning Michael J. Brosnan P.D.--P974806
MICHAEL J. BROSNAN P.D.
June 25, 1997
Secretary, Federal Trade Commission
Dear Mr. Secretary:
In response to the Commission's request for additional comments following the hearing held June 10, 1997, I as a Licensed Private Detective am a regular user of public and non-public (such as credit headers) records and I support the proposition of self-regulation.
The data that we regularly access and use in our reports to clients has a beneficial use and need in society. It is important that a free flow of information be available to support commerce and our judicial system. It also allows the general public, who does not have the resources to manage all of the problems faced on a daily basis, to fend for itself without looking to the government for help. Further regulation would create additional barriers to us that, today, save lives, prevent and detect fraud, and bring families together.
We are required to keep the information confidential and maintain a high degree of accuracy in our reports due to the guidelines of the law, the courts, and the marketplace. To have the targets of our investigations able to browse around our inquiries and data, or opt out of the public and private data bases, would be the death of our industry and a curb on freedom. The prevention of wrong doing and the detection of fraud are real tests for the use of data.
Privacy protection can be managed through our industrys self-regulation of use and distribution of information. Our industry has stated a willingness and a desire to self-regulate. This industry must have the opportunity to self-regulate and welcomes the governments assistance in enforcing rules through our industrys efforts.
I ask that you support self-regulation and work with the industry to successfully bring about policies and procedures we can all live with in a free society.
Michael J. Brosnan
Michael J. Brosnan P.D.