COMMENTS OF NARROW LINE CONCERNING CONSUMER ON-LINE PRIVACY-P954807 NARROW LINE 340 Bryant Street, Floor 3 New York San Francisco Secretary, Federal Trade Commission Dear Secretary of the FTC, I am writing to express my interest in participating in Session Two of your Workshop on Consumer Information Privacy, scheduled for 10-13 June 1997. I am the Executive Vice President of Research and Information Architecture for Narrowline, a small company with offices in San Francisco and New York City. Narrowline's primary product is an information system that facilitates the process of buying and selling targeted Internet advertising; in support of this system, our research group is involved with Internet-administered surveys. I believe that, because of Narrowline's relationships with dozens of Internet content providers (WorldWide Web sites, mailing lists for announcements and discussions, etc.), dozens of Internet advertisers, and thousands of Internet end users, we are in a unique position to share information relevant to participants in your Workshop. It is, perhaps, worth noting that Narrowline, while dependent on the success of Internet advertising for our own success, takes a strong position on the side of consumer privacy and privacy policy disclosure. We serve on the Steering Committee of and are a charter participant in the eTRUST project, and we fundamentally believe that a large part of the appeal of this new medium is its inherent freedom to explore ideas. Should consumer privacy fears -real or imagined - begin to restrict this freedom of exploration, the Internet will fail to live up to its remarkable potential. In particular, I would like to address question 2-4 of your Consumer Online Privacy Invitation to Comment. As part of our ongoing research efforts, we have collected, or are in the process of collecting, information from Internet end users about their perceptions and expectations regarding collection and use of personal information. It is worth noting that the scope of our surveys goes beyond the World-Wide Web, and sheds light on similar opinions regarding Unsolicited Commercial E-mail (especially questions 2.16 through 2.19). Our surveys address the specific issues raised in
question 24. and, perhaps more importantly, study the
issues of third party involvement (e.g., the case where
an invisible networked third party is able to aggregate
consumer behavior more effectively than any individual
Internet content provider) and technological solutions
(e.g., encryption or cookie (token) management tools). Yours truly, Eric S. Theise, Ph.D. |