December 3, 1999

Mr. Eric Fredell
Task Force on Electronic Commerce
International Trade Administration
Department of Commerce
Fourteenth Street & Constitution Avenue, N.W.
Washington, D.C. 20230

Dear Mr. Fredell:

I am writing in response to David Aaron's notice of November 15, 1999, which sets forth proposed "Frequently Asked Questions" (FAQs) and revised International Safe Harbor Privacy Principles in connection with EU privacy standards.

IBIA, the trade association for the biometric industry, believes that the proposed FAQs and revised Principles reflect the best interests of U.S. companies operating in EU markets. As those Principles are implemented, IBIA urges the Department to respect the specific concerns of the biometric industry expressed in IBIA's letter of comment dated November 19, 1998, a copy of which is enclosed. IBIA's core concern is to ensure that policymakers understand that biometrics are powerful means to secure personal privacy and deter identity theft.

To promote a better understanding of biometrics and learn more about the issues faced by the Department, we would welcome the opportunity to meet again with you and other appropriate officials responsible for data privacy matters. Please phone me so that we can fix a convenient date and time to meet.

Sincerely,

Richard E. Norton
Executive Director

Enclosure