April 15, 1997
Secretary, Federal Trade Commission
RE: Data Base Workshop -- Request to Participate, P974806
Dear Mr. Secretary:
In response to the Commission's Notice Requesting Public Comment and Announcing Public Workshop ("Notice"), issued March 4, 1997, the National Council of Investigation and Security Services, Inc. (NCISS) requests the opportunity to participate in Session One of the Public Workshop on Consumer Information Privacy, scheduled for June 10, 1997.
NCISS is an association of about 1000 security and investigative companies, large and small, across the United States, serving individuals, businesses and government agencies. Our membership also includes the state associations representing all licensed private investigators and security services in 36 states. Founded in 1972, our mission focuses on training, education and advocacy on behalf of the private sector security and investigative industries. NCISS has participated actively in proceedings involving a number of state and federal privacy and information policy issues, including most recently the inquiry of the Board of Governors of the Federal Reserve System on the risks to insured depositary institutions of the availability of sensitive consumer identification information.
In terms of the focus of Session One, NCISS represents a significant sector of customers of databases defined in the FTC's Notice as "look up services," as well as operators of such databases and suppliers of data thereto. NCISS's participation in Session One of the workshop would promote a balance of interests, and would advance the consideration and discussion of issues raised by the FTC's study of the databases in question. NCISS and its representatives have expertise in and first-hand knowledge of the issues that are the focus of the study, and in its participation would reflect the views
of a range of firms within the private sector security and investigative industries. Because of the range of perspectives that NCISS can offer to the FTC, we respectfully request the opportunity to present a panel of four to six speakers at Session One, including the undersigned.
NCISS's preliminary comments on the issues outlined in the Notice are attached. We request the opportunity to supplement these comments at a later stage of this proceeding.
NCISS would greatly appreciate the opportunity to participate in Session One of the Public Workshop, and looks forward to the Commission's favorable response to this request. If we may provide any further information, please do not hesitate to contact either of the undersigned, or counsel.
Gary H. Kuty, President
Jack H. Reed, First Vice President
Steven J. Metalitz