Advisory Committee on Online Access and Security – Nomination, P-004807

January 5, 2000
Submitted by Robert E. Lewin
CEO/Executive Director of TRUSTe
(408) 342-1945

TRUSTe respectfully nominates Paula J. Bruening, Director of Compliance and Policy for TRUSTe, to serve on the Federal Trade Commission Advisory Committee on Online Access and Security. Ms. Bruening would serve as a valuable resource to the committee as it provides advice and recommendations to the Commission regarding implementation by commercial Web sites of the fair information practice principles of access and security.

Founded in 1997, TRUSTe is a nonprofit organization dedicated to elevating trust and confidence in the Web by addressing the issue of privacy. The TRUSTe program is based upon the principles of fair information practices, including notice, choice, security, and access. Participants that incorporate each of these in its data practices in its privacy policy, as well as allow for TRUSTe’s Watchdog consumer complaint mechanism, are awarded the TRUSTe privacy seal to display on their Web site. Today, the TRUSTe privacy seal can be found on over 1000 Web sites, which includes all of the Internet "portals," 15 of the top 20 most visited sites and more than 50 percent of the top 100 sites.

In her position at TRUSTe, Ms. Bruening is responsible for guiding companies to apply fair information practices. As a result, Bruening is intimately familiar with the real-world challenges of applying fair information practices to the day-to-day operations of a company doing business online. Similarly, Ms. Bruening is responsible for helping companies understand the legal and public policy ramifications offor not abiding by these principles. This practical experience and awareness of the privacy landscape has been a critical component in both growing the TRUSTe program and raising the bar of current business privacy practices online.

Ms. Bruening’s present position is informed by her prior work in the area of privacy and security. Before joining TRUSTe, she served as Senior Attorney-Advisor to the Office of the Chief Counsel, National Telecommunications and Information Administration of the U.S. Department of Commerce. At the Department of Commerce, Ms. Bruening was involved in the privacy policy debate, participating in the development of the Administration’s self-regulatory approach to privacy protection. In this effort, she was the principle drafter of the staff discussion paper "Elements of Effective Self Regulation for Protection of Privacy."

In her work for the U.S. Congress at the Office of Technology Assessment, she closely examined, among other Internet and information policy questions, issues of information security and privacy in her work on two publications, "Protecting Privacy in Computerized Medical Information," and "Information Security and Privacy in Networked Environments." These documents provided the Congress with analysis of technology developments and options to address emerging policy questions about privacy and security issues.

As a result of her public policy experience and her current role at TRUSTe, Ms. Bruening will clearly be an asset to the committee. She will provide valuable insight to its efforts to consider the parameters of reasonable access to personal information, adequate security to protect that information and finally, to deliver a report of policy options and the consequences of their implementation to the Commission.

Thank you for considering this nomination and do not hesitate to contact me if you have any questions.

Bob Lewin
CEO/Executive Director