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

January 5, 2000

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

Dear Mr. Clark:

Pursuant to the Federal Register notice of Tuesday, December 21, 1999, I respectfully nominate Dr. Larry Ponemon for membership on the Advisory Committee and hereby submit his resume for your careful consideration.

Dr. Ponemon is a Partner and Global Leader of Compliance Risk Management for PricewaterhouseCoopers LLP. He is also the founding partner of our Privacy Risk Management practice, which is responsible for auditing the privacy practices for a wide array of companies and industries, including e-business, insurance, banking, telecommunications, health care and others.

Dr. Ponemon’s participation would be of particular value with respect to the Committee’s stated task to "consider how to define standards by which the adequacy of measures taken by Web sites to protect the security of personal information gathered online may be judged; what might constitute the reasonable steps to assure the integrity of this information; and what managerial and technical measures should be undertaken to protect this information from unauthorized use or disclosure." Dr. Ponemon’s participation will reflect the interests and perspectives of providers of third party verification of compliance, which is a critical element in any self-regulatory enforcement process for privacy protection and the assurance by data handlers of consumer’s rights to access their personal information.

Dr. Ponemon has significant experience as a consultant and educator on issues relating to ethical business practices, including practices in the Internet. I know that Dr. Ponemon would be truly honored to have this opportunity to serve the Federal Trade Commission. Please feel free to contact me at 202-414-1379 or Dr. Ponemon directly at 212-596-8369 for more information.

Dr. Patrick Sullivan

Cc: Dr. Larry Ponemon