Mary Lou Roberts

To: Federal Trade Commission

From: Philip Quaglieri, Dean
College of Management
University of Massachusetts Boston

Subject: Nomination to the Federal Trade Commission Advisory Committee on
Online Access and Security

As stipulated in the Federal Trade Commission Request for Nominations, I am pleased to nominate Mary Lou Roberts, Professor of Marketing at the University of Massachusetts Boston, to a seat on the Advisory Committee on Online Access and Security.

Dr. Roberts has served on a variety of advisory and governance boards during her professional career. Most relevant, she served two three-year terms as an American Marketing Association representative to the Bureau of the Census's Advisory Committee of Professional Organizations, completing her final term in April 1996.

Of greater significance to the activities of this committee, she is widely recognized in the community of marketing academics for her work in the field of consumer data protection and privacy. She published her first papers on the topic in the proceedings of two European conferences in 1992 and has continued to the present with a recent presentation to a conference on database marketing and marketing research in Washington, D.C. Her cases Geocities (A) and (B) will be published in the next edition of the Journal of Interactive Marketing. The cases are currently available for inspection on her web site http://omega.cc.umb.edu/~dirmkmg on the Cases/Original Cases page.

Dr. Roberts is senior author of a text which is an international leader in its field--Direct Marketing Management (2nd ed., Prentice-Hall, 1999). The topic of consumer data privacy is prominent in the introductory and interactive marketing chapters of the text and is discussed in other contexts. The definition of direct marketing in this text reflects the perspective the authors want students to take from the course:

Databased direct marketing is an information-driven, relational marketing process that takes place in a context of concern for the privacy of customer data. (p.3)

The text, as well as Dr. Roberts' other scholarly work, recognizes global differences in privacy approaches, especially the inconsistencies between the requirements of the European Union Privacy Directive and practices in other countries including the United States.

Her personal perspective is strongly stated in presentations to students, academic organizations, and marketing executives from various parts of the world. It reflects a preference for self-regulation, based in part on the speed of technological change in the field. It also recognizes that marketers of all types, especially marketers on the Internet, have failed to deal effectively with the issue. Additionally she notes that consumers, even active Internet users, are not well informed about data privacy and security even though they voice substantial levels of concern about these topics.

Overall, I believe Dr. Roberts meets the three criteria stated in your Request for Nominations:

1. She brings the perspective of the direct/database/Internet marketing industry and academics who teach this subject matter, but she is in no way an apologist for the failures or oversights of the industry.

2. Her knowledge of marketing strategy and consumer behavior issues in this area is her great strength, but she has a solid understanding of the technology that enables data-driven marketing programs.

3. Dr. Roberts maintains a positive working relationship with leading businesses and practitioners of databased marketing and with the Direct Marketing Association through its Educational Foundation. She is, however, an outspoken critic of privacy abuses and of the damage they do to legitimate practitioners of the discipline.

I hope I have given you the information you need to give this nomination serious consideration. If there is anything else I can do to facilitate your consideration, please do not hesitate to call on me.

cc: Mary Lou Roberts
P.O. Box 31
N. Eastham, MA 02651
508-255-7166
robertsml@capecod.net