Comments to FTC on National Credit Reporting Agencies and Free Reports: Credit Reports Most People Have Never Heard Of

We urge the Commission to study national consumer reporting agencies sooner rather than later and to issue regulations giving consumers' access to free reports. In our 12-year history we have received many complaints from individuals who have been harmed or otherwise disadvantaged because of erroneous or inappropriate information in such consumer reports.

Medical Records Privacy: Fears and Expectations of Patients

The title of this talk is "Medical Records Privacy: Fears and Expectations of Patients". So you can get an understanding of my point of view, I want to start out by talking about our project, the Privacy Rights Clearinghouse, and then make several points about the topic.

Joint Comments to the California Department of Insurance Proposed Regulations RH 03031129: Property Loss Databases

A crisis exists in California's homeowner's insurance market. In May of this year, the Department noted a four-fold increase in the number of consumer complaints about homeowner's insurance, topping the Department's complaint hotline.2 Non-renewal of coverage was a leading cause of consumer complaints, nearly always based on information included in a CLUE or A-Plus report. Adverse insurer decisions based upon inaccurate information included in reports was also a leading cause of consumer complaints.

One of the most troubling practices noted was that of a consumer's insurance being cancelled simply because the individual made an inquiry to the insurer without ever having filed a claim for loss.

Comments to the California Department of Insurance Proposed Regulations ER05043832: Property Loss Databases

The Privacy Rights Clearinghouse (PRC) is please to write in support of the Department’s continuing efforts to protect California consumers from adverse insurance decisions based on error ridden claims history reports. A steady stream of consumer complaints filed with the Department as well as the PRC’s experience with consumer concerns make further action by the Department both justified and necessary.

Consumers Can Get Free “Specialty” Consumer Reports Starting December 1, 2004

SAN DIEGO, CA – The arrival of free credit reports on December 1st is getting a lot of attention these days. (www.ftc.gov/bcp/conline/pubs/credit/freereports.htm) But there is another kind of report, called “specialty consumer reports,” that individuals can obtain at no charge beginning on the first of the month. The federal law that requires credit reporting bureaus to provide free reports is the Fair and Accurate Credit Transactions Act, also known as FACTA. The law also gives consumers the right to one free report prepared by a “nationwide specialty consumer reporting agency” that compiles files on consumers.

“Pay As You Drive” Automobile Insurance: Comments on the Need to Guard Personal Privacy

On June 18, 2008, PRC and Privacy Activism responded to a call for comments when DOI first considered adopting a pay-drive program.

Our June 2008 comments discuss the serious threats to privacy inherent in a pay-drive program that depends on data gathered by onboard technology. Our concerns extended not only to the kinds of data collected by installed devices but also to the potential and unforeseen secondary uses of collected data. With few exceptions, our concerns about the threats to privacy and potential secondary uses of data remain essentially unchanged from those expressed in June 2008.

“Pay As You Drive” Automobile Insurance: The Need to Guard Personal Privacy

Privacy Rights Clearinghouse and PrivacyActivism agree that a pay-drive plan that offers financial incentives for those who drive infrequently or who may choose to carpool or take public transportation has enormous potential for reducing traffic and protecting the environment. However, we respectfully disagree with the Commissioner’s statements in his August 3, 2009, press release that the regulations protect the privacy of California drivers.

Also, regrettably, neither the Department’s press release nor the amended regulations explain how the privacy of California drivers is protected.

“Pay As You Drive” Automobile Insurance: Recommendations for Guarding Personal Privacy

Along with the potential good to come from reduced driving through PAYD insurance, there is a real risk that insurers will base attractive premiums on consumers’ willingness to accept onboard devices that record much more than miles traveled. Depending on the technology used, devices installed on personal automobiles may track speed, location, duration of a trip, acceleration and deceleration, time of day the trip was made, the identity of the driver, use of mobile phones and more. Once installed, a device originally set to track one driving element may be altered to add additional functions.

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