Before the

Federal Trade Commission

Washington, DC 20580

December 2, 1997



In the Matter of: )

)

Deceptive Internet Sites )

Collecting Personally Identifiable Health Information )

Without Disclosing Its Intended Use )

__________________________________________)


Complaint and Request for Investigation







Submitted to:

Donald Clark

Office of the Secretary

Federal Trade Commission

6th Street & Pennsylvania Ave. NW

WDC, 20580

Before the

Federal Trade Commission

Washington, DC 20580

In the Matter of: )

)

Deceptive Internet Sites )

Collecting Personally Identifiable Health Information )

Without Disclosing Its Intended Use )

__________________________________________)

Complaint and Request for Investigation

I. Introduction

The Center for Democracy and Technology (CDT) files this Complaint and Request for the Federal Trade Commission (FTC) to investigate the practices of World Wide Web sites:

CDT believes that Heartinfo.org and Asthmacontrol.com are engaged in the unfair and deceptive practice of collecting personal health information from Web site visitors without providing adequate information about the intended use of the information. CDT believes that Heartinfo.org and Asthmacontrol.com are undertaking marketing, product development, list compilation and other research using personal information obtained from visitors to their sites. This practice harms consumers by depriving them of information necessary to make an informed decision about the use and disclosure of their personal health information.

The ease with which information can be collected directly from individuals and gathered surreptitiously through technologies that track visitors digital footsteps across the Web presents new challenges to protecting individual privacy. As news stories, government forums, and on-line discussion groups focus on the growing market for personal information, public concern with the collection of personal information online continues to escalate.

During the Federal Trade Commission's November 1995 workshop, "The FTC's Consumer Protection Role in the Emergining High-tech, Global Marketplace," CDT stated that without the ability to control the flow of personal information individuals would be reluctant to participate in the growing online environment. Our prediction that consumer privacy concerns would undermine the potential of the Internet as a forum for communication, education, and commerce has been confirmed. At the Commission's June 1997 Workshop, two surveys were released: both revealed that privacy concerns are stifling Internet growth. Survey results showed that individuals are particularly concerned with the collection and use of their, or their children's, personal information without their consent.

Protecting privacy has emerged as a critical component of developing a trusted environment for communication and commerce online. The failure of Web sites to provide full information about their data practices and to provide individuals the ability to make informed decisions about the use and disclosure of their personal information undermines individual privacy and is detrimental to the growth of the Internet.

CDT requests that the Commission order Heartinfo.org and Asthmacontrol.com to cease and desist the practice of collecting information from consumers without providing full and accurate notice and gaining consent, and to provide the specific relief requested.

II. The Parties

A. The Center for Democracy and Technology

The Center for Democracy and Technology (CDT) is a non-profit, public interest organization incorporated in the District of Columbia and operating as a tax-exempt organization. CDT is dedicated to preserving and enhancing democratic values and civil liberties on the Internet and other interactive communications media. CDT pursues its mission through public education, grass roots organizing, litigation, and coalition building.

Central to CDT's mission is the principle that people must be able to maintain control over personal information in order to fully realize other core values, including autonomy, liberty, free expression and civic participation. The ease and pace with which information about people's activities and communications online can be collected, stored and reused present new challenges to privacy. However, CDT believes that the interactive and flexible nature of new communications media can enhance individual control over personal information. Through public policy, advocacy, and work with the technical and business communities, CDT seeks to ensure that policy and technology develop in ways that protect privacy and empower individuals to control their personal information.

B. Heartinfo.org

Heartinfo.org is run by the Center for Cardiovascular Education Inc., based in New Providence, NJ. The site describes itself as "an independent, educational Web site that provides a wide range of information and services to heart patients and others interested in learning about lowering risk factors for heart disease." (Exhibit 1) The site states that it was founded by a "heart patient" and a "physician, who is a world renowned expert on heart disease." (Exhibit 2)

The Heartinfo.org Web site provides a range of information to assist individuals suffering from heart disease including links to a variety of resources on heart disease, a question and answer section where registered users can query "experts," and information on "heart-healthy" products. (Exhibit 3)

The Heartinfo.org site came to the attention of CDT staff when the SmithKline Beecham site promoting Ecotrin disappeared from the World Wide Web and all traffic was rerouted to Heartinfo.org. (Exhibit 4) Heartinfo.org is sponsored by "pharmaceutical and medical imaging companies, cardiac treatment centers, providers of health care products and services, companies that provide low-fat and heart healthy foods, exercise and cardiovascular fitness companies, and other heart-related businesses." (Exhibit 5 & 6) Although sponsors are listed, CDT believes that Heartinfo.org does not fully disclose the nature of its relationships with sponsors including the use and/or disclosure of personal information gathered from visitors to aid sponsors in research, marketing, and product development.

C. Asthmacontrol.com

Asthmacontrol.com is run by Glaxo Wellcome Inc., based in Research Triangle Park, N.C., a subsidiary of London-based Glaxo Wellcome plc. Glaxo Wellcome Inc. is a research-based pharmaceutical firm. Glaxo Wellcome plc is an integrated, research-based group of companies that discovers, develops, manufactures and markets pharmaceuticals, and develops care and cost management programs (like pharmacy benefit management programs). (Exhibit 7)

The Asthmacontrol.com Web site provides a range of information to assist individuals suffering from asthma, including downloadable documents to assist in predicting and managing the illness and a library of asthma-related resources. (Exhibit 8)

III. Statement of Facts

A. Heartinfo.org

Heartinfo.org encourages visitors to register. Only registered members are entitled to participate in the question and answer section where they can seek advice from medical experts. In addition, registered members are able to participate in special awards programs and receive coupons and discounts from site sponsors. While sections of the site are available to unregistered visitors, the welcome page's "Get started" icon leads to a page that immediately "encourage[s] all of our readers to take a moment to become a member of Heartinfo. Membership is free and it only takes a minute to complete the registration form." (Exhibit 9)

1. Information Collected during Registration

The Heart Information Network Registration form (Exhibit 10) contains three fields identified as mandatory:

Following the mandatory fields are ten health-related questions which inquire about the individual's:

The questions about medication usage ask visitors to identify:

Following the questions about health, three optional questions are asked. Visitors are asked to "Please provide this (see below) information if you would like to receive coupons and special offers and discounts from our sponsors:"

2. Stated use of information

The member benefits section states that this information is collected:

The only additional disclosure about information use is located prior to the collection of a visitor's address, phone and fax numbers, where it states:

B. Asthmacontrol.com

Asthmacontrol.com encourages visitors to register. Registered members receive a "free kit full of the latest information to help you understand and manage your asthma..." (Exhibit 8) Although much of the content at Asthmacontrol.com is accessible without registering, the welcome page entices visitors to register by suggesting it will help them "prevent attacks before they happen," (Exhibit 8) and limiting access to the Asthma Control Program Handbook and Personal Tracker, and Asthma Network to registered members.

1. Information Collected during Registration

The "Asthma Kit Electronic Registration Card" (Exhibit 11) asks visitors to provide the following information:

In addition, the registration form asks visitors if they are interested in receiving information about asthma products and/or nasal allergy products, or on another topic.

2. Stated use of information

The Asthmacontrol "Asthma Kit Electronic Registration Card" tells visitors that the information will be used to place individuals on their mailing list. In addition, the form states that "you can make sure that you will continue to receive asthma-related news and treatment options, important reports and other helpful tools from Glaxo Wellcome on a regular basis." The form states that Glaxo Wellcome will keep the information "confidential." (Exhibit 11) No other uses of personal information are disclosed to visitors.

IV. The Heartinfo.org site is deceptive and misleading in violation of Section 5 of the FTC Act.

The Commission will find a violation of Section 5 of the FTC Act if there is a representation, omission, or practice that is likely to mislead the consumer acting reasonably under the circumstances, to the consumer's detriment. According to the Federal Trade Commission Policy Statement on Deception, the Commission considers three core elements: first it must find a representation, omission or practice that is likely to mislead the consumer; second, the act or practice must be viewed from the perspective of a consumer acting reasonably in the circumstances; and third, the representation, omission, or practice must be "material", such that it is likely to affect the consumer's conduct or decision with regard to a product or service.

A. Heartinfo.org's failure to fully disclose the uses of consumers' personal health information is misleading.

Heartinfo.org's failure to fully disclose the uses of consumers' personal health information is misleading. CDT believes that Heartinfo.org is using personal health information provided by consumers for product and market research and possibly disclosing information in non-identifiable, aggregate, and personally identifiable form to its sponsors. If our belief is accurate, then Heartinfo's failure to fully disclose its intended use of personal information is misleading.

The site misleads consumers by obscuring the full purpose of the consumer's interaction with Heartinfo.org. We believe that the site is collecting personal information for a number of purposes, including product and market research and the creation of marketing lists, which are not revealed to visitors. By stating that information will be used for the purposes of "mak(ing) Heartinfo a better site" and providing registered members with "coupons and special offers and discounts from our sponsors," Heartinfo.org is implying that information will be used solely for the two identified purposes. Consumers are likely to rely on the affirmative statement of intended use in deciding whether to disclose sensitive health information to Heartinfo.org. Because the statement is incomplete, consumers will mistakenly believe that information will only be used to send them coupons and improve the site. Heartinfo.org's failure to inform consumers of the additional uses and disclosures of personal information, which CDT believes are occurring, is misleading.

1. Misleading representations

In earlier cases, the Commission has found a representation misleading where a sales person misrepresented the purpose of the initial contact with customers. For example, in the Matter of Encyclopedia Britannica the Commission found that Britannica's sales representatives' description of home visits as primarily for the purpose of conducting surveys and brand analysis was misleading where the true purpose for the visit was to sell merchandise.

The affirmative statements about the use of information made by Heartinfo.org to visitors during the registration process can be likened to the facts in the Britannica case. Similar to the misleading representation in Britannica, CDT believes that Heartinfo.org is misrepresenting its true intentions with regard to the use of personal information gathered from visitors and is encouraging consumers to engage in an interaction -- providing personal information -- based on incomplete information. When Heartinfo.org affirmatively states that it will use information for specific purposes, a reasonable consumer is likely to infer that no other uses will be made of this information.

When exploring deception claims, the Commission and courts examine the representation within the context of the overall document, taking into consideration the juxtaposition of various phrases, the nature of the statement, and the type of transaction involved. In this instance, the positioning of the statements of information use at the point of collection bolsters the implication that information gathered from visitors by Heartinfo.org is not being used for other purposes or by other entities. Taken as a whole, the representation made by Heartinfo.org is likely to mislead consumers.

2. Misleading omission

If Heartinfo.org is using information for marketing research, product development and list compilation, its failure to disclose these practices is an omission likely to mislead consumers. The Commission has found that the omission of "material" information can be misleading. In some circumstances, the Commission presumes that an omission will lead consumers to draw false conclusions about the product or service. In other instances, the Commission has required evidence about consumers' expectations prior to finding an omission to be misleading.

In Beneficial, the court upheld the Federal Trade Commission's order finding that the use of personal information gained through the preparation of tax returns for soliciting loans without disclosure to consumers was a false, misleading and deceptive practice injuring consumers. The Commission reasoned that the relationship of tax preparer and client would lead to the mistaken belief that the information would be used only for the purpose of tax preparation and maintained confidentially. Therefore, the Commission ruled that Beneficial's failure to disclose its intent to use personal information collected during the tax preparation process was misleading. In upholding the Commission's order, the court held that requiring Beneficial to disclose to consumers:

were rationally related to the FTC's attempt to alleviate unfair practices. In upholding the FTC's ruling, the court noted that the context within which the information was solicited would lead "to the mistaken belief that the information would be used only for that purpose and maintained confidentially" therefore the omission of information was misleading.

Similarly, the public-positioning of the Heartinfo.org Web site as an "independent, educational Web site" may encourage consumers to perceive the site as a trusted entity operating solely in the consumer's best interest and maintaining information confidentially. Like Beneficial, Heartinfo has positioned itself as a "trusted" party to whom consumers can reveal sensitive information about their health. The lack of adequate disclosure about Heartinfo.org's use and possible disclosure of personal health information to assist its corporate sponsors is, taken in context, likely to mislead consumers. Here too, the goal of alleviating deceptive practices would be met by requiring full disclosure of all intended uses of personal information.

If Heartinfo.org is using and disclosing sensitive health information to assist corporate sponsors in their product and market research, which CDT believes it is, then, absent a clear and conspicuous notice, Heartinfo.org is misleading consumers.

B. Consumers acting reasonably in the circumstances are likely to believe that Heartinfo.org is not using or disclosing their personal information for additional purposes.

Heartinfo.org's statements regarding the use of personal information is likely to mislead a reasonable consumer under the circumstances. A reasonable consumer is likely to believe that Heartinfo.org will only use personal information for the purposes stated at the site. Unless consumers are provided with information about other uses of their sensitive health data, they are unlikely to foresee them.

Consumers are often unaware of the reuse and disclosure of personal information they provide to others during daily transactions. While the Internet and other interactive media are shedding new light on the large market for personal information, consumers are still shocked to learn that information about their activities ranging from online browsing to grocery shopping is used for a variety of purposes and made available to other companies without their permission. When individuals become aware of the availability of personal information, many take steps to protect it. Lexis Nexis witnessed one such demand last August when thousands of consumers called, emailed, and faxed in requests to be removed from the P-Trak service. Services such as P- Trak, which provide "credit header" information, have been available for quite some time, however most consumers were unaware of their existence. Similarly, AOL subscribers recently told the company that providing their phone numbers to telemarketers was inappropriate -- despite the fact that the practice of selling/renting subscriber phone numbers is common in the marketing industry.

Unless consumers are informed that their information will be used for other purposes and disclosed to others they likely to rely upon the affirmative statements of information use made by the site. The site's non-profit image and "org" domain designation are likely to quell suspicions consumers may have when interacting with commercial entities in the marketplace.

C. Given a full and fair disclosure of intended uses and disclosures of information a portion of consumers acting reasonably in the circumstances would not disclose sensitive health information; therefore, Heartinfo.org's failure to disclose other uses of the personal information they collect from visitors is "material."

Consumers acting reasonably in the circumstances would find Heartinfo.org's use and disclosure of personal information for other purposes relevant to their decision to provide information. Consumers consider health and financial information to be their most sensitive personal information. A bevy of surveys over the past five years have documented a heightened concern with the privacy of medical information, and an even deeper concern with the automation of medical information.

Four findings of the 1993 Health Information Privacy Survey may be particularly useful in determining whether Heartinfo.org's failure to disclose its' use of individuals' health information for marketing and product research and development is "material." The 1993 Survey found that:

The survey data indicates that a reasonable consumer would object to the use of her personal health information for research and marketing purposes without her consent.

In its recent Advisory Letter regarding the collection of personally identifiable information from children online, the Federal Trade Commission staff took note of survey evidence introduced during its June 1997 Privacy Workshop that supported the assertion that an omission was "material." The Survey data indicated that parents generally objected to the collection, use and disclosure of information from children. This data lent support to the Commission's finding that Spectracom's statement that personally identifiable information was being collected from a child for a particular purpose when the information was also being used for another purpose, absent a clear and prominent disclosure to that effect, was deceptive. The survey data indicated that given full information a reasonable parent would object to the request for information, therefore the omission was material.

In the case of health information, the survey data reveals that people are opposed to its use without their consent. In light of survey data indicating that well over half of the public believes that personal health information should not be disclosed or used for marketing or research without their consent, CDT believes that a reasonable consumer given full and accurate information about the intended uses of information would not disclose details of their health information to Heartinfo.org. The survey data also supports the proposition that individuals would want requests for research uses of their health information to be limited in scope -- to a specific entity, for a specific project, for a limited duration, and with appropriate safeguards. Based on survey data, CDT believes that Heartinfo.org's failure to disclose the intended marketing and research uses of data gathered from consumers injures consumers by depriving them of the ability to make meaningful decisions about the use of sensitive health information.

Since information about additional uses and disclosures of health information would influence some consumers' decision to provide personal information, Heartinfo.org's omission is "material." The Commission's Policy Statement on Deception states, "Where the seller knew, or should have known, that an ordinary consumer would need omitted information to evaluate the product or service. . . materiality will be presumed because the manufacturer intended the information or omission to have an effect. Heartinfo.org's statements imply a limited use of personal health information. Heartinfo.org is withholding information critical to consumers' decision to disclose information. CDT believes that Heartinfo.org knew, or should have known, that consumers would need full information about its intended uses of personal information to evaluate Heartinfo's request for personal information.

Without a complete, clear and conspicuous statement of Heartinfo.org's information practices consumers are unable to make informed choices about the appropriate use of their personal health information. Consumers have indicated that personal health information should only be used with their informed consent. Heartinfo.org's failure to provide adequate notice to consumers is harmful in that it deprives consumers of the information necessary to make a meaningful decision and control the use of personal health information.

V. The Asthmacontrol.com site is deceptive and misleading in violation of Section 5 of the FTC Act.

The Commission will find a violation of Section 5 of the FTC Act if there is a representation, omission, or practice that is likely to mislead the consumer acting reasonably under the circumstances, to the consumer's detriment. In determining whether a given act or practice is deceptive three criteria must be considered by the Commission. The Commission must find a representation, omission or practice that is likely to mislead the consumer. The act or practice must be viewed from the perspective of a consumer acting reasonably in the circumstances. And, the representation, omission, or practice must be "material", such that it is likely to affect the consumer's conduct or decision with regard to a product or service.

A. Asthmacontrol.com's failure to fully disclose the uses of personal health information provided by consumers is misleading.

CDT believes that Glaxo Wellcome is using information gathered at Asthmacontrol.com for marketing and research purposes. If CDT is correct, Asthmacontrol.com's failure to disclose its intended use of personal information is misleading.

Consumers can be misled by direct misrepresentations, by implications drawn from an accurate but incomplete statement, or by omissions. If CDT's belief is correct, Glaxo Wellcome is misleading consumers in two ways: 1) by affirmatively stating that information will be used for a limited purpose, consumers are led to believe that it won't be used for other purposes; and, 2) by failing to disclose other uses of personal information Glaxo is withholding information material to consumers decision to provide information.


1. Misleading representation

By stating that information will be used to "place individuals on their mailing list" and to "make sure that you will continue to receive asthma-related news and treatment options, important reports and other helpful tools from Glaxo Wellcome on a regular basis" Asthmacontrol.com is implying that information will be used solely for the two identified purposes. Based on this representation, a reasonable consumer may conclude that information will not be used for other purposes.

In examining implied claims, the Commission and courts examine the representation within the context of the overall document, taking into consideration the juxtaposition of various phrases, the nature of the statement, and the type of transaction involved. Although the Asthma Kit Electronic Registration Card states that:

Additionally, you can make sure that you will continue to receive asthma-related news and treatment opinions, important reports and other helpful tools from Glaxo Wellcome on a regular basis. All information will be kept confidential by Glaxo Wellcome

the name and URL of the site may confuse consumers. The name and URL of the Web site obscure its relation to Glaxo Wellcome, a large research-focused pharmaceutical company, and may bolster the implication that information gathered from visitors is not being used for other purposes. Written information about Glaxo Wellcome is not provided at the site. A URL allows users to find out information about Glaxo Wellcome from the parent company Web site. If, as CDT believes, Glaxo Wellcome is using this information for other purposes the affirmative, but incomplete, representations made at the site are likely to mislead consumers by encouraging a false belief that the site only uses information for the stated purposes.

2. Misleading omission

If Glaxo is using information for marketing research, product development and list compilation, its failure to disclose these practices is an omission likely to mislead consumers. In some cases the Commission has found that the omission of material information, the disclosure of which is necessary to prevent the claim, practice, or sale from being misleading is deceptive. In some circumstances, the Commission presumes that an omission will lead consumers to draw false conclusions about the product or service. In other instances, the Commission has required evidence about consumers' expectations prior to finding an omission to be misleading.

Asthmacontrol.com positions itself as an information resource for asthma suffers. It does not advertise itself as a product oriented Web site. Consumers who are unaware of Glaxo Wellcome's business are unlikely to suspect that information they provide at Asthmacontrol will be used for other purposes. The lack of adequate disclosure about Glaxo Wellcome's interest in and use of personal health information collected at Asthmacontrol.com is, taken in context, an omission likely to deceive consumers.

If Glaxo Wellcome is using sensitive health information collected at Asthmacontrol.com to conduct product and market research, which CDT believes it is, absent a clear and conspicuous notice to consumers it is misleading consumers.

B. Consumers acting reasonably in the circumstances are likely to believe that Asthmacontrol.com is not using or disclosing their personal information for additional purposes.

Asthmacontrol.com's statements regarding the use of personal information is likely to mislead a reasonable consumer under the circumstances. A reasonable consumer is likely to believe that Asthmacontrol.com will only use personal information for the purposes stated at the site. Unless consumers are provided with information about other uses of their sensitive health data, they are unlikely to foresee them. The sites URL which obscures its tie to Glaxo Wellcome and format as a resource center are likely to foster this misperception.

C. Given a full and fair disclosure of intended uses and disclosures of information a portion of consumers acting reasonably in the circumstances would not disclose sensitive health information; therefore, Asthmacontrol.com's failure to disclose other uses of the personal information they collect from visitors is "material."

Consumers acting reasonably in the circumstances would find Asthmacontrol.com's use and disclosure of personal information for other purposes relevant to their decision to provide information. Consumers consider health and financial information to be their most sensitive personal information. A bevy of surveys over the past five years have documented a heightened concern with the privacy of medical information, and an even deeper concern with the automation of medical information.

Four findings of the 1993 Health Information Privacy Survey may be particularly useful in determining whether Asthmacontrol.com's failure to disclose its' use of individuals' health information for marketing and product research and development is "material." The 1993 Survey found that:

The survey data indicates that a reasonable consumer would object to the use of her personal health information for research and marketing purposes without her consent.

In its recent Advisory Letter regarding the collection of personally identifiable information from children online, the Federal Trade Commission staff took note of survey evidence introduced during its June 1997 Privacy Workshop that supported the assertion that an omission was "material." The Survey data indicated that parents generally objected to the collection, use and disclosure of information from children. This data lent support to the Commission's finding that Spectracom's statement that personally identifiable information was being collected from a child for a particular purpose when the information was also being used for another purpose, absent a clear and prominent disclosure to that effect, was deceptive. The survey data indicated that given full information a reasonable parent would object to the request for information, therefore the omission was material.

In the case of health information, the survey data reveals that people are opposed to its use without their consent. In light of survey data indicating that well over half of the public believes that personal health information should not be disclosed or used for marketing or research without their consent, CDT believes that a reasonable consumer given full and accurate information about the intended uses of information would not disclose details of their health information to Asthmacontrol.com. The survey data also supports the proposition that individuals would want requests for research uses of their health information to be limited in scope -- to a specific entity, for a specific project, for a limited duration, and with appropriate safeguards. Based on survey data, CDT believes that Asthmacontrol.com's failure to disclose the intended marketing and research uses of data gathered from consumers injures consumers by depriving them of the ability to make meaningful decisions about the use of sensitive health information.

Since information about additional uses and disclosures of health information would influence some consumers' decision to provide personal information, Asthmacontrol.com's omission is "material." The Commission's Policy Statement on Deception states, "Where the seller knew, or should have known, that an ordinary consumer would need omitted information to evaluate the product or service. . . materiality will be presumed because the manufacturer intended the information or omission to have an effect. Asthmacontrol.com's statements imply a limited use of personal health information. Asthmacontrol.com is withholding information critical to consumers' decision to disclose information. CDT believes that Asthmacontrol.com knew, or should have known, that consumers would need full information about its intended uses of personal information to evaluate Asthmacontrol.com's request for personal information.

Without a complete, clear and conspicuous statement of Asthmacontrol.com's information practices -- including a description of Glaxo Wellcome and its access to and use of personal health information -- consumers are unable to make informed choices about the appropriate use of their personal health information. Consumers have indicated that personal health information should only be used with their informed consent. Glaxo Wellcome and Asthmacontrol.com's failure to provide adequate notice to consumers is harmful in that it deprives consumers of the information necessary to make a meaningful decision and control the use of personal health information.

VI. Conclusion and request for relief

If CDT's beliefs are correct, Heartinfo.org and Asthmacontrol.com are engaged in deceptive practices. The failure of the sites to clearly and conspicuously disclose the research and product development uses (and perhaps disclosures) of the personal health information collected from site visitors misleads consumers to their detriment. The sensitive nature of the personal information at issue, the well-documented consumer privacy concerns, and the serious consequences the individual may suffer if health information is misused require a full and comprehensive notice to consumers.

In light of relevant precedent and recent guidance, CDT respectfully requests that the FTC order both sites to cease and desist from collecting personal health information without:

In addition to the relief above, CDT respectfully requests that the FTC order both sites to

A growing number of pharmaceutical companies are using the World Wide Web to gather data from individuals. (Exhibit 12) CDT believes that if the current practice of collecting personal health information without full disclosure and informed consent continues, individuals' privacy will be compromised and their sensitive health information will be subject to growing misuse and abuse.

Respectfully submitted,



Deirdre K. Mulligan

Staff Counsel