FTC: Consumer Privacy Comments Concerning Bates Investigations--P974806 BATES (512) 502-1111 July 8, 1997 Mr. Robert Pitofsky, Chairman RE:Support of Self Regulation Dear Mr. Chairman: In response to the Commission's request for additional comments following the hearings held June 10, 1997, I, as a licensed private investigator, am a regular user of public and non-public records (such as credit headers), and support the proposition of self-regulation. The data 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 the problems they are faced with, to defend itself without looking to government for help. Further, regulation would create additional barriers to use that today save lives, prevent 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 law and the test of the courts and marketplace. To have the targets of our investigations able to browse around in our inquiries and data, or opt out of databases that are private and public would be the death of our industry and freedom. The prevention of wrongdoing and protection of fraud are real test of the use of data. Private protection can be managed through our industry's self-regulation of uses and distribution. Our industry has 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 our efforts and the industry's associations. 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 Ken BatesKen Bates KB/sc |