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.

JetBlue: Complaint for Violations of CA Business and Professions Code Sections 17200, et seq.


JetBlue Airways Corporation ("JetBlue"), through an agreement with Torch Concepts, acting in its capacity as a subcontractor for SRS Technologies, provided the personal information of over a million passengers, some of whom are located in California, without such passengers' authorization or consent and in violation of JetBlue's stated privacy policy not to share without consent any passenger data with any third parties.

Albertsons' Pharmacies: Complaint for Violations of CA Business and Professions Code Sections 17200, et seq.


Albertsons promotes their access to its customers'/consumers' confidential medical information to pharmaceutical companies anxious to increase the name recognition and sale of their drugs. Albertsons secretly enters into commercial arrangements with pharmaceutical companies willing to pay to participate in the Drug Marketing Program. Albertsons then allows these pharmaceutical companies to participate in using the consumers' medical information for direct marketing (either directly by Albertsons or through direct marketing services companies) that increases the sale of targeted drugs. The pharmaceutical companies fully finance the Drug Marketing Program.

Letter to House of Reps. and Senate to Oppose HR 2622


The Privacy Rights Clearinghouse and the Identity Theft Resource Center urge you to oppose H.R. 2622 as written because it preempts many state consumer protection laws while failing to prevent credit bureau mistakes or stop identity theft.

Consumer Group Analysis of House FCRA Legislation, H.R. 2622


This memo provides a section-by-section analysis of H.R. 2622, which was reported out of the House Financial Services Committee on July 25th. Although the bill takes some steps to prevent identity theft, improve accuracy and protect medical privacy, it fails to offer meaningful solutions to the most important problems that were identified in Senate and House hearings, especially given that the quid pro quo for these measures is permanent and perhaps expanded preemption of state laws.

RFID and the Public Policy Void


If ever there were a technology calling for an in-depth multi-disciplinary holistic analysis involving all stakeholders, it is RFID. Yet this technology has sprung upon the scene with little attempt so far to address its many probable adverse impacts upon society. It does not take a great deal of reflection to understand the profound privacy and civil liberties implications associated with RFID if indeed all the "things" of the world are uniquely identified and can be located and read at a distance.

What's Missing from This Picture?: Comments to FTC "Information Flows" Workshop


"The free flow of information." This phrase has a deceptively appealing ring to it, almost patriotic in tone. We have heard it used frequently by industry representatives during the workshop today. What are some of the consequences of the free flow of information?

Letter to the FTC on Job Search Industry Privacy Concerns


We are writing to draw your attention to the challenges consumers face as they search for jobs in today's rapidly evolving, information-rich environment. Both online and off, the machinery of the information economy has created a high demand for large compilations of job seekers' names, email addresses, and resumes. Perversely, the demand for job seeker information does not correlate to the availability of jobs nor the demand for workers.

Public Records on the Internet: The Privacy Dilemma


One of the most challenging public policy issues of our time is the balancing act between access to public records and personal privacy - the difficulty of accommodating both personal privacy interests and the public interest of transparent government. I will discuss the privacy implications of making public records containing personal information available on the Internet. I list nine negative consequences of the availability of public records online. I conclude by offering 11 recommendations for safeguarding personal privacy while upholding the public policy reason for providing access, that being to promote government accountability.

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