The Saga of Shredding in the U.S.: A Privacy Advocate's Perspective


Even though since those "early years" in our identity theft work shredding has become a household word and shredders are a common household item, trash is still a lucrative source of Social Security numbers and other useful bits of personal information for those who perpetrate identity theft.

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.

PRC Rebutts Newspaper Editorial Lauding Full Disclosure of Personal Information of Campaign Contributors on www.fundrace.org


Your March 30th editorial on the website www.FundRace.org has it wrong. You tell people "there's no reason to fear" the fact that their name, home address, occupation, and campaign contribution information is on the Internet for all the world to see. But many individuals have very legitimate reasons to not want their home address posted on the Internet.

Federal Agencies' Joint Request for Comment: Alternative Forms of Privacy Notices


The Gramm-Leach-Bliley Act (GLB) requires financial institutions to give customers annual notice of how personal information is collected and disclosed, and, under limited circumstances, a means for customers to control information flow. The notices delivered to consumers, beginning with the effective date of July 1, 2001, until now have generated substantial criticism from all interested parties. As the ANPR notes, there have been broad-based concerns expressed by representatives of financial institutions, consumers, privacy advocates, and Members of Congress.

In response to numerous concerns expressed by all stakeholders about privacy notices, the FTC convened a workshop in December 2001, just five months after financial institutions were required to send the initial privacy notice to customers. To further address these continuing concerns, the Agencies have published the ANPR. That the Agencies are willing to revisit the issue of clear notice to consumers by considering a short-form notice is an encouraging sign for consumer privacy interests.

Statement on Outsourcing and Privacy


We at the Privacy Rights Clearinghouse commend Senator Figueroa and the two Senate Committees for conducting a hearing on outsourcing, and for considering not only the employment implications but also the potential risks to the privacy and security of records containing sensitive personal information. I restrict my comments to the issues of privacy and security.

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.

RFID Implementation in Libraries


We recommend that the library community conduct a comprehensive technology assessment of RFID as soon as possible to enable librarians to make the best possible decisions involving the implementation of this technology. Such a risk-benefit analysis would include an investigation of the potential privacy and civil liberties implications and the best methods to mitigate these harms.

Prevent Identity Theft with Responsible Information-Handling Practices in the Workplace


Discussions on preventing identity theft often focus on steps consumers can take, such as shredding their trash and restricting access to their Social Security number (SSN). But realistically, while such measures can reduce the odds of becoming a victim, there is little individuals can do to actually prevent identity theft. The keys to prevention are two-fold, involving the credit industry and the workplace:

Federal Agencies' Guidelines regarding Notification by Financial Companies when a Security Breach Compromises Customer Data and Exposes Individuals to Identity Theft


The Agencies' current proposal establishes guidance for financial institutions' response programs for unauthorized access to customer information. The proposal also includes guidance on when notice to customers is necessary.

Recent studies have confirmed that the crime of identity theft claims millions of victims each year, costing both victims and financial institutions billions of dollars in losses.3 Financial institutions that collect and maintain personal customer information as part of business operations have a legal obligation to establish security procedures to maintain the confidentiality and integrity of that data.

Groups Submit Comments to National Banks Agency Opposing Preemption of States


The OCC's proposed revisions to 12 CFR Parts 7 and 34 of its regulations identify certain types of state laws that would be preempted for non-real estate loans made by national banks.

The scope of the OCC's proposal potentially affects consumer protection and privacy laws of many states. However, we limit our comments to the potential impact on California laws. Particularly troubling is the uncertain implication of the OCC's rulemaking for important identity theft laws that involve access to, and use of, credit reports. Of equal concern is the OCC's proposed regulation to preempt state laws that require national banks to give mandated statements to be included in billing or credit related documents.

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