FTC: Consumer Privacy Comments Concerning Area Wide Investigations--P974806

AREA WIDE INVESTIGATIONS
1244 Karla Drive Suite 206, Hurst, Texas 760 53-4437
817/285-8480 800/258-9643 817/280-0507 fax

Mr. Robert Pitofsky, Chairman, Federal Trade Commission
Room H-1 59
Sixth & Pennsylvania Avenue N.W.
Washington, DC 20580

July 10, 1997


Re:Support of Self Regulation

Dr. Mr. Chairman:

In response to the Commission's request for additional comments following the hearings held June 10, 1997, I Leo Holden 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 an dour judicial system. It also allows the public, who does not have the resources to manage all of 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 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 tests of the use of data.

Privacy 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.

Respectfully submitted.

Leo E. Holden

cc: Hon. Kay Bailey Hutchinson, Senator
Hon. Kay Granger, Representative