Peggy H. Haney
Vice President
Consumer Affairs

American Express Company
801 Pennsylvania Avenue., NW
Suite 650
Washington, DC 20004
Tel: 202.434.0158
Fax: 202.625.0775

January 5, 2000

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

Advisory Committee on Online Access and Security – Nomination, P004807

Dear Secretary Clark:

I would like to submit my name in nomination as a member of the Federal Trade Commission’s Advisory Committee on Online Access and Security. I believe that I can represent the interests of diverse financial services companies such as American Express who have made privacy and security an integral part of how business is conducted.

Our more than twenty-five year history of privacy protection – including my personal involvement in this effort since 1981 – will contribute a perspective based on experience. This experience includes developing the company’s Customer Privacy Principles issued in 1991 and their subsequent implementation. More recently, I led a senior level task force that completed a review of the Principles in 1996 in order to update them and to review our compliance and reporting processes. Ensuring security of personal data is one of our Privacy Principles and was included as a part of the review. I am very familiar with the Fair Information Practices since the American Express Customer Privacy Principles are based on these practices.

As part of the implementation of the Principles following the 1996 review, I led the creation of an Internet Privacy Statement, which directly applies the broadly stated Privacy Principles to this new medium with its complex privacy and security issues. Ongoing responsibility for implementation includes review of new products, services and policies to be sure that our Privacy Principles are built into the design of each.

I also bring considerable experience in formulating public policy around privacy having actively participated in the formation of the Online Privacy Alliance and the Better Business Bureau Online Privacy Program. In addition, over the years, I have created American Express sponsored privacy education materials for pubic school use and brochures for consumers.

I believe this experience in every aspect of privacy has prepared me to be a strong contributing member of the FTC Advisory Committee on Online Access and Security. In addition, I will have the benefit of drawing on the depth of expertise within the company in areas that may require insight into the security, operational, and technological business processes of a major multi-national financial services organization.

Since access is a topic with major implications for American Express business processes and with potential large costs, I am familiar with the issues. I have spoken at length with consumer leaders about privacy issues including access and am well versed in the complexities of the debate. Based on my responsibilities noted above for ensuring the privacy of personal information through our Customer Privacy Principles, and the experience of American Express with its millions of customers who expect and receive a high level of privacy and security, I believe I can provide a balanced and helpful perspective to the Advisory Committee and sub-committee deliberations. I also can commit to the schedule of meetings noted in the Federal Register report.

Thank you for your consideration.

Peggy H. Haney