COMMENTS OF MCGRAW-HILL COMPAINES CONCERNIG CONSUMER ON-LINE PRIVACY-P954807
1221 Avenue of the Americas
Barbara A. Munder
The McGraw-Hill Companies
April 15, 1997
Mr. Donald S. Clark
Re: Consumer Privacy 1997 -- Request to Participate, P954807
Dear Mr. Clark:
On behalf of The McGraw-Hill Companies, I am pleased to respond to your request for comments on consumer privacy in an on-line environment and commend the Federal Trade Commission (FTC) for its leadership on this issue and diligence in guarding the rights of consumers in this new environment. Each business and consumer engaged in electronic commerce has a stake in this debate. Certainly a key issue to be thoughtfully explored involves the direct or indirect collection and use of personally-identifiable information.
The business community and consumers have much to learn about how to conduct electronic commerce responsibly. Government regulators and legislators also have a great deal to learn about consumer expectations, legitimate reasons for and benefits of businesses' collection of personally- identifiable information and its subsequent uses, the state of technology in helping consumers make choices, and the viability of well-devised industry self-regulation. The upcoming FTC public workshop on consumer information privacy undoubtedly will provide an appropriate forum for learning more about this complex and important issue.
As you may be aware, The McGraw-Hill Companies is a global publisher and financial services provider, with locations in over 40 states and offices literally around the world. We employ more than 12,500 employees domestically and 2,000 additional employees overseas. We serve worldwide markets in education, business, industry and government and provide information in print through books, magazines and newsletters; online over electronic networks; over the air by television and satellite; and on software, videotape, facsimile and CD-ROMs. As a corporation dedicated to educating and empowering individuals with information, our relationship with our customers is of paramount importance. We recognize that our customers' trust in our products and business integrity is among our most valuable assets. We feel strongly that it is incumbent upon businesses to ensure that their practices are appropriate to maintain customer trust, and to ensure that customers' reasonable expectations to privacy are met. We also must educate consumers about the benefits derived from certain personally-identifiable information data collection, such as customization of products to better meet consumer needs, fulfillment of orders and product requests and customer awareness of products specifically meeting their needs and interests.
To ensure that this compact with our customers is responsibly met, The McGraw-Hill Companies comprehensively has reviewed our existing policy and is revising the policy to reflect the changing digital environment and consumers' expectations. Central to the policy are several basic tenets, including notice, consumer choice, and procedures to safeguard particularly "sensitive" personally-identifiable information. We also are developing extensive implementing guidelines to supplement the policy and assist employees in translating the policy into reality. The McGraw-Hill Companies recognizes the importance of responsible policy in this area and is committed to making this new policy a central part of the corporation's culture and operating practices.
Obviously, it is not sufficient to merely revise our policy and educate employees about it. We also must communicate our policy to consumers and educate them about the legitimate reasons businesses collect personally-identifiable information. To facilitate this communication and education, we actively are developing methods to make our policy readily available to consumers in both a print and digital environment. We encourage other businesses to similarly develop and implement comprehensive policies and educate consumers about them. The FTC also has an important role to play in this education and communication process. Through events such as the upcoming workshop and similar fora, and by continuing to post helpful information on its website to alert consumers to both the benefits and pitfalls of data collection by businesses, the FTC can play an important educational role for consumers and assist businesses in getting the positive message of industry self-regulation to consumers.
Customer trust in The McGraw-Hill Companies and its products is the foundation of our business. We would be pleased to participate in the upcoming forum and discuss the steps we are taking -- development of our new policy and the methods used to implement the policy and measure compliance -- to ensure that this valuable asset is preserved and fostered.