January 5, 2000

Secretary of the Commission
Donald S. Clark
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, NW
Mail Stop 4429
Washington, DC 20580

RE: Advisory Committee on Online Access and Security – Nomination, P004807

Dear Mr. Secretary:

I am writing to nominate myself to one of the positions on the Advisory Committee on Online Access and Security. As announced on December 16, 1999, the Advisory Committee is charged with considering the parameters of reasonable access to personal information and adequate security to protect such information and with offering options for implementation of these fair information practices and the costs and benefits of each option.

I believe that my work as both legal counsel and as an issue manager for LEXIS-NEXIS Group and its parent company Reed Elsevier, Inc. will allow me to bring to the Advisory Committee substantial real-world experience with these issues.

As outlined in the attached resume, I have been employed in the online industry since 1984 and have worked on technology and information management issues most of my career.

I represent Reed Elsevier, Inc., including its subsidiaries and operating divisions, on issues related to information privacy, online privacy and information access. Reed Elsevier is a world leading publisher and provider of information services, whose operations include the LEXIS-NEXIS online information service and the Martindale Hubbell, and Marquis Who’s Who directories. Reed Elsevier is also significantly engaged in the direct marketing industry, both as a source of marketing lists, through Cahners Business Information, and as a marketer of goods and services.

I am the Chairman and President of the Individual Reference Services Group (IRSG), the first meeting of which was convened at the request of LEXIS-NEXIS in 1997. The IRSG is the first of a new breed of industry self-regulatory efforts, designed to bring both substance and accountability to self-regulatory programs. The IRSG Principles address specifically the use and availability of personally identifiable information in locator services, one of the first privacy issues to come to national attention more than three years ago. The IRSG addresses those concerns directly and effectively. I participated in all stages of the formation and development of the IRSG and of the IRSG Principles and related documents.

I serve as co-chair of the Privacy Committee of the Software and Information Industry Association, the leading trade association of the information industry and of information service providers. The SIIA, and its’ predecessor the IIA, has long been involved in privacy issues related to the collection of information about individuals and access to and use of public records.

I represent Reed Elsevier at the Online Privacy Alliance (OPA) and was involved in the development of the OPA Guidelines for Online Privacy Policies and related documents. The work also laid the foundation for much of the work of the Better Business Bureau OnLine (BBBOnLine) and other self-regulatory efforts. This massive collaborative effort has helped not only to further acceptance of the fair information practices principles noted in the FTC's announcement of the Advisory Committee, but has propelled the debate forward to the current focus on the issues of access and security.

The work of BBBOnLine is critical in bringing substance and consumer recourse to self-regulation and the collection of information online. My involvement in that effort came as a member of both the Privacy Steering Committee and the Dispute Resolution Committee.

Also on behalf of Reed Elsevier, I am a member of the Alliance for Fair Information Practices --which is addressing privacy concerns in the state of California -- and the Coalition for Sensible Public Records Access (CSPRA). The latter is seeking a reasoned approach to information access and disclosure policies in the states for public records.

I am willing to commit to attend all of the scheduled meetings of the Advisory Committee if appointed. I am also willing to work in good faith, as I have on similar collaborative efforts on this issue, with the other members of the Advisory Committee and the Commission to develop a sound approach to the issues before the Advisory Committee.

I appreciate your consideration of my nomination. Please let me know if you need further information on my qualifications.

Very truly yours,
Steven M. Emmert