The Proliferation of Online Information Brokers and Reports of Abuses of Consumer Privacy


The Privacy Rights Clearinghouse (PRC) appreciates the opportunity to submit the following comments on the online information broker industry to the Federal Trade Commission (FTC) as part of the agency’s deliberations for the Privacy Roundtables series.

The online information broker industry has come to the forefront of consumer privacy issues in recent years. Information brokers are companies that compile information on individuals via public, semi-public and private records and offer this information via online “lookup” services, often with no questions asked. Some charge a fee while others provide their services at no charge. Consumers who are attempting to limit the availability of their personal information, due to concerns about privacy, safety or identity theft, have lodged numerous complaints against this industry with the PRC over the years.

Interagency Proposal for Model Privacy Form under the Gramm-Leach Bliley Act


The Privacy Rights Clearinghouse (PRC)1 is pleased to comment on the Federal Trade Commission (FTC or Commission) notice of proposed rulemaking (NPR)2 to simplify the consumer disclosures required by the Gramm-Leach-Bliley Act (“GLB”). With only a few minor suggestions, the PRC endorses and fully supports the model form adopted by the agencies. We direct our comments as follows:

New Look for Prescreened Credit and Insurance Offers


tarting August 1, 2005, unsolicited offers for credit or insurance that are based on information in your credit report should be easier to spot.

New regulations adopted by the Federal Trade Commission now require notices to prominently display the toll free number (1-888-5OPTOUT or 1-888-567-8688) to opt-out. Now, this number, along with a statement that you can stop the unsolicited offers, must appear - in at least 12-point type - on the first page of the offer.

Consumer Notice Requirements for Opting Out of Pre-Approved Offers of Credit


For years, consumers have received preapproved credit offers with required notices and opt-out telephone numbers buried in fine print along with other mandatory legal notices. We support the Commission’s proposal to provide a layered notice. The proposal calls for a “short notice” on the principal promotional document. The short notice includes the most important information, including opt-out telephone number, with direction to a “long notice” located elsewhere in the solicitation.

PRC Recommends Wireless Cell Phone 411 Directory Should be Complete Opt In


The Privacy Rights Clearinghouse (PRC) advocates that the wireless 411 directory that is slated to be launched in early 2005 provide a strict opt-in mechanism that requires express consent before cell phone numbers are listed in the directory. The PRC also believes that federal legislation should be strengthened to ensure this standard is met.

"We believe there are several reasons to recommend the opt-in standard, one being privacy," said Jordana Beebe, PRC Communications Director. Though the wireless industry touts their directory will be an opt-in standard, Beebe counters, "We are also concerned about the unregulated wireless industry overseeing the directory without legislative oversight."

Financial Privacy Notices: Shorter is Better


For business, the goal should be not only to provide a notice that satisfies the legal requirement, but one that consumers can easily understand. Although practices may vary from company to company, the bottom line is always the same: Companies either share information with affiliates and third parties or not. Consumers either have the right to opt-out or they don't.

San Mateo Co. (California) Board of Supervisors Unanimously Adopts Financial Information Privacy Ordinance


Redwood City - The Board of Supervisors unanimously adopted an ordinance today to protect consumers' financial information privacy. With this ordinance, San Mateo County has become the first jurisdiction in California to provide consumers privacy protections in excess of those found in federal law, Gramm-Leach-Bliley Act. This ordinance would require financial institutions to ask for and receive consumerís permission before disclosing consumerís confidential information to third parties.

North Dakota Votes for "Opt-In" Financial Privacy


On June 11, 2002, voters in North Dakota spoke overwhelmingly in favor of financial privacy. A referendum which would prohibit banks from sharing, selling or otherwise disclosing personal financial information succeeded by a majority of three to one. This confirms what polls have been telling us for years. Consumers feel strongly about privacy, particularly when it comes to the sensitive information in bank records.

2001: The GLB Odyssey -- We're Not There Yet: How Consumers Rial Privacy Notices and Recommendations for Improving Them


Given the complexity and limitations of GLB's privacy provisions, the Privacy Rights Clearinghouse (PRC) undertook a major project to educate consumers about the new law and their right to prevent information sharing. The PRC launched this project with the premise that such an educational program would fill the gap left by questions unanswered from consumers' review of the notices required by GLB. Instead, what we found was that the majority of consumers who contacted us had heard or read media stories about the GLB notices and realized they had ignored the notices that their financial institutions had mailed to them in previous months. Few of the consumers who contacted us had actually noticed or read the notices. They were worried that they had missed the opportunity to prevent the sharing of their customer data with other companies.

Confusing E-Mail about Opt-Out Number Sends the Wrong Message


An unknown individual has broadcast an electronic mail message that has reached tens of thousands of consumers, confusing them with information that is only half correct.

The message explains, erroneously, that as of July 1, 2003, "the four major credit bureaus in the US will be allowed . to release your credit info, mailing addresses, phone numbers..... to anyone who requests it." This is not correct.

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