FTC: Consumer Privacy Comments Concerning The Interactive Services Association (ISA)--P954807
TESTIMONY OF THE
PANEL II: SELF REGULATORY APPROACHES TO ONLINE PRIVACY ISSUES
JUNE 11, 1997
JEFF B. RICHARDS
The Interactive Services Association (ISA) appreciates the opportunity to appear before the Federal Trade Commission today. The ISA's member companies have been at the forefront of many of the interactive industry's new developments and we look forward to working with the FTC on this crucial and developing part of our industry.
The ISA is the leading trade association representing more than 300 companies devoted exclusively to promoting and developing consumer online, Internet and interactive services worldwide. Among its members, the ISA count key providers of consumer Internet and online services, such as America Online, AT&T, Bell Atlantic, CompuServe, IBM, Microsoft, Netscape, NETCOM, and Prodigy. These are firms, along with a host of interactive marketers and online content providers, who worked last year and over the last several months to design and revise the ISA Privacy Principles.
1996 to Today
Last year, the ISA worked in coordination with the Direct Marketing Association to design a series of guidelines that fit the need of many of our mutually-shared members and that addressed concerns and set principles for notice and opt-out for online marketers, and marketing to children online. This year, the ISA and the DMA pursued individual approaches that specifically suited the needs of their individual memberships. This by no means diminishes the quality of the work that was completed last year; to the contrary, the work of the ISA and the DMA was the foundation of the ISA's recently completed guidelines. It is obvious that privacy is and will continue to be one of the more conspicuous concerns of both the consumer and business communities in online and Internet services. The ISA continues to work with the DMA and a variety of other to meet the concerns of consumers while seeking to balance the needs of ethical online business operators.
1997 ISA Principles
Thus, the ISA has worked over the last year with its member companies to construct a series of more comprehensive principles that adequately reflect not only technological trends, but also the changing desires of the consumers affected by these trends. The following is a brief synopsis of our submitted testimony on the ISA Privacy Principles for 1997:
Let me be clear: I do not believe that any single organization has every needed answer. Thus, ISA is working closely with the National Consumers League, the Center for Democracy and Technology, the Internet Privacy Working Group, the Information Technology Association of America, and Privacy and American Business, to name just a few.
At the same time, ISA members and much of the larger interactive industry saw that consumers had a variety of expectations about their own privacy. The ISA has long recognized that consumer trust and awareness is a critical foundation to the goal of achieving widespread and central use of interactive services in society. Lack of adequate regard for consumer privacy could set the stage for a negative perception of the industry or individual providers, quashing usage. Thus, privacy approaches may be a competitive advantage as competition intensifies and consumers grow more educated.
The full text of the new ISA principles have been submitted to the Commission, and are being disseminated via the ISA's web site and through other means.
The thrust of ISA's work is this: consumers must be informed about the practices of the providers with which they do business, and then have an opportunity to act on that information. This is the next challenge of consumer education and empowerment: to use the very tools of interactivity to the benefit of consumers, and thus to strengthen the understanding of and bond between providers and customers.
In sum, privacy for the online consumer -- and weaving it seamlessly into the technological developments of tomorrow -- is one of the more vexing and necessary aspects of the interactive industry. The ISA principles are a blueprint for the online and Internet providers of today to set the practices of tomorrow. The ISA will continue to monitor and evolve with the changing privacy concerns of the industry and its consumers, and we are accelerating our public education work hand-in-hand with ISA members.
The ISA appreciates the FTC's willingness and forward looking approach to dealing with privacy. This very crucial component of the online and Internet services environment is all of our concern and we are grateful for this chance to present our views.