I-Behavior Inc.
75 South Broadway ( 4th Floor
White Plains, NY 10601
Phone 914-302-4040 - Fax 914-302-4041
January
3, 2000
Secretary
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, NW
Washington, DC 20580
Advisory Committee on Online Access and Security - Nomination, P004807
The purpose of this letter is to nominate Lynn Wunderman for appointment to the Advisory
Committee on Online Access and Security. Ms. Wunderman is uniquely qualified for the
position, as outlined against the following selection criteria:
- Would promote a balance of points of view represented and functions to be performed by
the panel.
- Has highly relevant expertise in the issues and technologies relevant to the
implementation of fair information practices by commercial Web sites.
- Is well positioned to represent of a broad range of interests affected by commercial Web
sites' collection of personal information on consumers.
Overview of Ms. Wunderman's Background
Ms. Wunderman's primary professional expertise is in the field of database marketing. She
has over 20 years of experience in the areas of strategic planning, database management,
market analysis, target audience and media segmentation as used in the offline Direct
Marketing Industry.
She is currently President, CEO of I-Behavior, a firm dedicated to serving the data and
information services needs of e-commerce marketers. I-behavior's services include a
co-operative database of opt-in on-line buyers, supported by an integrated suite of
services, including Database Consulting and Management, Analytical Services and
the-I-Behavior Data Lab (a provider of strategic consulting, behavioral research and
product development services).
Prior to founding I-Behavior, Ms. Wunderman was a founding partner of Wunderman, Sadh
& Associates, a consulting firm specializing in information-based marketing services
for both consumer and business-to-business marketers in the financial services, high-tech,
graphic arts, non-profit, and Internet industries -- with a particular focus on the needs
of multi-channel companies.
From 1992 to 1998, Ms. Wunderman was President and C.O.O. of Marketing Information
Technologies, a company providing database services for major Internet and Fortune 100
companies. Ms. Wunderman was formerly Senior Vice President, Director of Strategic
Planning and Information Management at Ogilvy & Mather Direct.
Ms. Wunderman is active in the Direct Marketing Association, having served as Vice-Chair
of the Marketing Council and on the Operating Committee of the Computer Council.
Currently, Ms. Wunderman serves on the Internet Committee of the DMA Board of Directors.
Criteria #1: Ms. Wunderman's ability to promote a balance of points of view
represented and functions to be performed by the panel.
Ms. Wunderman's participation will promote a balance of points of view because she has a
direct, personal stake in the outcome of online data and privacy issues. Her company will
prosper and grow to the extent that it is able to effectively acquire and analyze online
consumer data. On the other hand, that business would be adversely affected if abuses of
consumer privacy by others, or misunderstanding of the issues by consumers, leads to
widespread consumer distrust or overly restrictive legislation.
Specifically, Ms. Wunderman's professional background qualifies her to hold a balanced
view of privacy issues. As a direct marketer, Ms. Wunderman has been professionally
involved with the collection and use of data for marketing applications for over 20 years.
She has held professional marketing positions within corporations, has served account
services and consulting roles to major corporations, and has managed companies serving in
a vendor capacity - all positions involving the strategic use of consumer data and
information to support marketing functions.
Ms. Wunderman has served leading corporations in the use of data for:
- Finding lists of high-potential prospects
- Development of segmentation tools to better predict and understand consumer behavior
- Compilation of their customer purchase and response data for building and maintaining
mutually-rewarding relationships with their buyers
Companies served include:
The Advertising Council America Online, American Express, Bristol-Myers, Carnation,
Citicorp, Club Med, Duracell, Kimberly-Clark, Kraft, HBO Video, IBM, Lever, Mattel,
Merrill Lynch, Nationsbank, NutraSweet, Olan Mills, Owens-Corning Fiberglas, Pantone,
Perrier, SmithKline Beecham, Time Warner, Paramount Pictures, Unilever, and Van
Kampen/American Capital.
Ms. Wunderman's current company is building the industry's first opt-in compiled
co-operative database of online purchase information on consumers. In this role, she is
actively involved in consumer privacy issues both for her firm and her firm's clients
contributing data into the co-operative list. I-Behavior's activities include:
- Researching industry standards and practices regarding published privacy statements
- Constructing privacy statements for member sites in compliance with I-Behavior's use of
their customer data
- Development of a turnkey rewards program to encourage buyer opt-in to the list of online
names and addresses
- Monitoring legal/press news items
No legal or ethical issue impacts Ms. Wunderman's professional activities more than the
issue of online consumer privacy. She is actively constructing a business designed to
respect consumer privacy while making state-of-the-art use of consumer data for the mutual
benefit of e-commerce marketers and their online customers.
Criteria #2: Expertise in the issues and technologies relevant to the
implementation of fair information practices by commercial Web sites.
Ms. Wunderman is a recognized expert on the strategic issues and applications of
technology involved in the collection and use of data for marketing purposes:
- She currently heads a company that is developing proprietary technologies for use in
managing the transactional data collected by e-commerce organizations (I-Behavior).
- She has been actively involved in the areas of offline consumer list rental and
processing, customer data capture, database design and maintenance, and the strategic use
of consumer data compilations and customer data analysis for over 20 years.
- She has managed companies responsible for the data capture, management and analysis of
purchase data gathered on the Web for such noted companies as America Online, IBM and
MyPoints.com.
Ms. Wunderman has a history of innovation in the application of traditional direct
marketing techniques to new media. She has pioneered such areas as the application of
direct marketing modeling techniques to the package goods industry, and the use of direct
mail modeling techniques to support selective insertion of advertising in print media. She
is now applying this experience to the use of new technologies for improved targeting
efficiencies on the Internet.
An active industry speaker on the uses of consumer data in building profitable customer
relationships, Ms. Wunderman was recently asked to sit on the annual conference program
committee of the National Council of Database Marketing.
Ms. Wunderman offers a combination of traditional direct marketing expertise along with
up-to-date experience in applying these tools to the area of e-commerce marketing.
Criteria #3: Representation of a broad range of interests affected by commercial Web
sites' collection of personal information on consumers.
Ms. Wunderman's professional activities routinely address the needs of different business
constituencies:
- E-commerce marketers
- E-marketing service companies/experts in interactive technology
- Trade associations (Her active role in the Direct Marketing Association/Association for
Interactive Media)
Recently, Ms. Wunderman was selected by the Direct Marketing Association's Board of
Directors to represent the industry on its Internet Committee. Her nomination to the
committee was based on her ability to fairly represent the data and privacy issues
relevant to the Internet community in fulfilling the committee's mission.
In addition, Ms. Wunderman is personally an active online consumer buying from Web
marketers and catalog companies with an online presence. She experiences first-hand what
happens to her personal data and is personally concerned for the rights of the buying
public.
Conclusion
Ms. Wunderman has exceptional professional qualifications that would be an asset to this
committee, and she will be an active and committed contributor to the committee's work
seeking an equitable, workable outcome.
Sincerely,
Lynn
Wunderman
President,
CEO |