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.

Groups Ask FTC to Stop Blocking Links to Free Credit Report Site, www.annualcreditreport.com


While a number of issues regarding www.annualcreditreport.com need to be corrected, one issue stands out as critically important to correct immediately. That is, the active blocking of Web linking to the annualcreditreport.com site is harming consumers right now, and does not serve any apparent purpose other than to direct consumers to for-pay services at the credit bureaus.

Comments to the Federal Trade Commission: Prerecorded Telemarketing Calls to Existing Business Customers (EBR)


For years intrusive, privacy invasive telemarketing calls have been a major source of consumer outrage.  Calls made by so-called “predictive” dialers -- automatic dialing that allows a telemarketer to call multiple households at one time -- have been a significant consumer complaint. Such calls are intrusive, invade the privacy of one’s home, and result in great annoyance when one races to answer the phone to find only dead air or a hang-up on the other end of the line. Predicative dialer calls are particularly troublesome and potentially dangerous for the elderly and the disabled.

Fair and Reasonable Fee for Credit Score Disclosure: Comments to Federal Trade Commission


For years lenders have relied on scoring models to evaluate risk in extending credit to individual consumers for a car loan, mortgage or credit card. Following the lead of states like California and Colorado, Congress amended the FCRA with the Fair and Accurate Credit Reporting Act of 2003, Pub. L. 108-159, (FACTA), and gave consumers the right to view their score as well as get an explanation of the factors that went into the score.

When consumer interests are factored in, the only fair and reasonable approach is for the Commission to set a fee limited to the actual cost of producing and delivering the score to consumers.

Financial Literacy and Education Campaign Strategies


Financial literacy should start early. Fundamental concepts such as the need for savings should be started in elementary school and be carried through the educational process.

Unfortunately, dysfunctional concepts such as “easy credit” are often instilled as college-age students are lured with multiple credit card offers and as television advertisements portray “the good life” as being fueled with credit card accounts. With the average household credit card indebtedness estimated at $9,000, these messages need to be countered early on with education about the responsible uses of credit.

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.

Privacy Rights Clearinghouse Files Lawsuit Charging Albertsons Violates Privacy of Pharmacy Customers


The Privacy Rights Clearinghouse (PRC), a San Diego-based nonprofit consumer information and advocacy organization, today announced that it has filed a lawsuit in California Superior Court charging supermarket giant Albertsons and its pharmacy units, SavOn, Osco, and Jewel-Osco, with violating the privacy rights of thousands of its customers by illegally using their confidential prescription information to conduct targeted marketing campaigns on behalf of drug companies.

Comments on FACTA Disposal Rule, RIN 3064-AC77: Fair and Accurate Credit Transaction Act Disposal of Consumer Report Information and Records


Irresponsible handling of sensitive consumer data has long been cited as a contributing factor to identity theft. A practice known as "dumpster diving" is often claimed by thieves themselves as the source of the data that allowed them to commit the crime. Sensitive data discarded by a financial institution provides a prime opportunity for a crook to access another's personal data.

By enacting §216 requiring proper disposal of consumer information, Congress has given the public one of the strongest tools yet in combating the growing crime of identity theft. It is now up to the financial regulators and the FTC to carry out Congress' intent by adopting strong regulations to ensure identity theft is no longer fed by careless and irresponsible disposal of confidential consumer data.

Study Shows Most Online Pharmacies Lack HIPAA Privacy Notice


The Privacy Rights Clearinghouse (PRC)1, along with readability expert Mark Hochhauser, Ph.D., is writing to call your attention to a recent survey of online pharmacies, and, in particular, the failure of most sites to post a HIPAA Privacy Notice.

In conducting this survey, Dr. Hochhauser visited 50 online pharmacy web sites. Of the 50, only 11 sites (22%) included a HIPAA Privacy Notice. The 11 sites that had a HIPAA privacy notice also posted a web site privacy policy.

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