From: "Robert Ellis Smith"
To: HQ.DCMAIL4(advisorycommittee)
Date: Wed, Dec 22, 1999 12:21 PM
Subject: Comments on On-Line FAC

Comments to the Federal Trade Commission on the proposed Advisory Committee on On-Line Access and Security

Over the past several months that concerns have been expressed about Web sites' collection of personal information, the concerns have focused on PRIVACY and CONSUMER PROTECTION. "Access" and "security" - although very important - have been secondary concerns. Thus, the proposed Federal Advisory Committee on On-Line Access and Security should be renamed appropriately, or the FTC should make clear that the mission of the advisory committee includes PRIVACY and CONSUMER PROTECTION. Otherwise, there seems no jurisdiction for the advisory committee to make recommendations about on-line profiling as described in the FTC's workshop and comment period last fall. Virtually all of the concerns expressed about on-line profiling focus on privacy and consumer protection, not access and security.

In addition, the FTC should include whenever it refers to a Georgetown University study in the spring of 1999 - as it did in its notice for the proposed advisory committee - that only 15 percent of the commercial sites surveyed posted notices saying that they abide by the generally accepted Code of Fair Information Practice and even fewer sites in the survey abide by the full code, including the principle on secondary use.

Robert Ellis Smith,
Privacy Journal
PO Box 28577,
Providence RI 02908