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APPENDIXES

Additional Letter And Statements

Prepared Statement Of Richard A. Barton, Senior Vice President, Government Affairs, Direct Marketing Association

My name is Richard Barton and I am Senior Vice-President of the Direct Marketing Association. I am very pleased to submit a statement on Caller ID Technology. I am even more pleased to state that the DMA supports legislative efforts including H.R. 4340, that requires suppliers of ANI and similar services to offer consumers the option of blocking the receipt of the ANI signal by commercial users.

I appeared before this subcommittee just two years ago to support this subcommittee's efforts to pass consumer privacy legislation in the context of the "Video Privacy Protection Act of 1988." That effort was successful with passage of a statute that very same year. We hope that our current efforts results in similarly positive action.

This past May, the Board of Directors of DMA adopted a

position on ANI and blocking. I would like to review that

policy paragraph by paragraph. First, DMA's position states as

follows:

The Direct Marketing Association (DMA)
recognizes that the proper use of technologv
such as automatic number identification (ANI)
benefits consumers. DMA also acknowledges the
privacv concerns that mav arise with the use of
such technology.

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ANI technology and Caller ID services provide significant technological advancements for direct marketers and the consumers that they serve. When a consumer calls a marketer the primary interest of the consumer is to communicate as accurately as possible and get off as quickly as possible. For the service provider speed and accuracy are also both important. ANI, by providing a means to link incoming calls with existing files, goes a great way to further the goals of speed and accuracy. The current application of ANI technologies allows an operator to see customer account information when she or he first says "hello". Once it is verified that the person calling is in fact the person identified by ANI, the operator can verify information which already appears in the caller's file rather than having to re-enter it for every call. Also, in some cases, particularly for on-line services like home banking, ANI will be very helpful in making sure that the person calling is in fact the authorized consumer. All of this will allow for faster, more accurate and more secure transactions.

ANI technology will also provide the marketer with the opportunity to retain the number of the party making the call. DMA guidelines require, however, that the marketer inform the consumer if information obtained as the result of a telephone contact is to be collected and made part of a mailing list rented sold or exchanged with others, and provide the consumer

with an opportunity to have his or her name stricken from that list.

ANI in concept is not new. DMA members for many years have received on a periodic basis from their long distance carriers the telephone numbers of people who have called their 800 and 900 numbers. Since the marketer is paying for these services it is appropriate that the marketer be informed of who made the call for billing purposes. Today, most marketers use either 800 or 900 numbers. Very little national marketing is done on the "regular" local or long distance network. ANI in the past has come in the form of paper printouts or computer tape.

What is new is the instantaneous delivery of the ANI number to the marketer at the time the call is received. What is also new is that this type of service can now be economically used by most marketers and not just the very large ones. The DMA believes that this is an important and essentially pro-consumer technology and that it should be able to develop with a minimum of regulation.

DMA also acknowledges that privacy concerns may arise with the use of this technology. These concerns relate to consumer knowledge. If a consumer has an unpublished number than he or she reasonably expects that such numbers will not be given to anyone else. Moreover, ANI technology should not be a basis for creating marketing lists unless the consumer has been so informed.

Primarily, the privacy concerns raised in this context relate to the more locally based Caller ID services which generally are not used by the marketing industry. While we believe that there is no threat to privacy by our industry's use of ANI services, we do recognize that there may be some positive steps that can be taken to avoid even perceived problems.

The DMA policy goes on to state:

In view of the direct marketing industrv's long
historv of supporting the opportunity of
consumers to limit the unwanted dissemination
of information about themselves, the Direct
Marketing Association intends to support those
legislative or regulatorv efforts that reouire
suppliers of ANI and similar services to offer
consumers the option of blocking the receipt of
the ANI signal bv commercial users.

DMA has long supported the practice of informing consumers of how information about them is to be used and to give them the opportunity to limit the dissemination of information about themselves. DMA's Mail Preference Service ("MPS") name removal file was established in 1971 in response to consumer requests to control their mail volume. A companion service, the Telephone Preference Service ("TPS) was established in January, 1985, as an answer to increased consumer inquiries regarding telephone marketing.

In 1977, the U.S. Privacy Protection Study Commission recognized MPS as an alternative to legislation regarding mailing list usage. The Commission also encouraged individual

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