FTC: Consumer Privacy Comments Concerning Lassen Investigative Services--P974806 Lassen Investigative Services P.O. Box 997 Susanville, CA 96130 916-251-2399 Fax: 916-251-5494 June 25, 1997 Secretary, Federal Trade Commission RE: Support of Self Regulation Dear Mr Secretary: In response to the Commission request for additional comments following the hearing held June 10, 1997, I, John Abbott as a licensed private investigator doing criminal defense investigations, am a regular user of public and non-public records (such as credit headers), and 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 public, who does not have the resources to manage all of the problems they are faced with to defend itself without looking to the government for help. Further regulation would create additional barriers to us that today save lives, ensure criminal justice, prevent fraud and bring families together. As a defense investigator I do not have access to the law enforcement records, including motor vehicle license information that the police have. Often times credit header information is the only way I have to locate witnesses that are critical to the defense case. In a recent case I was attempting to locate a critical witness who no longer lived or was employed at the locations listed in the police report. By using credit header information I was able to locate a current address on this individual even though he had moved numerous times in several states. Without access to the credit header information I would have been unable to locate this critical witness. As a retired law enforcement fraud investigator it is my professional opinion that these restrictions will not protect privacy or prevent fraudulent activity. I have worked numerous cases involving the fraudulent acquisition of credit information. In the majority of those cases the information was obtained through methods that this legislation would not prevent. As a private investigator I am required to keep information confidential and maintain a high degree of accuracy in my reports due to requirements of law, the rest of the courts and the market place. To have the targets of our investigations be able to browse around in our inquires and data, or opt out of the data bases that are private and public would be the death of our industry and freedom. The prevention of wrongdoing and the prevention of fraud are real tests of the use of data. Privacy protection can be managed through our industries’ self regulation of uses and distribution. Our industry had stated a willingness and desire to self regulate. This industry must have the opportunity to self regulate and welcomes the government’s help in enforcing the rules through the industries efforts. I ask that you support self regulation and work with the industry to successfully bring about policies and procedures that we can all live with in a free society. Sincerely, John AbbottJohn Abbott, PI 17324 |