Electronic Commerce Task Force
U.S. Department of Commerce
We have reviewed the revised Draft International Safe Harbor Privacy Principles released on March 17, 2000 and all of the other associated documents. We again express our appreciation for the extensive and diligent efforts expended by the Department of Commerce in addressing this important issue and the opportunity to provide our comments below.
FAQ 13 - Travel Information
We appreciate the changes made to this question since the November 15, 1999 draft to explicitly include reference to hotel reservations. While we believe the answer to the question implicitly includes hotel "frequent guest" programs, and we would maintain the position that frequent guest programs are included, we again strongly urge you to explicitly include frequent guest programs in the question and answer. This change would add only two additional words to the question and answer and eliminate the need to infer the inclusion of frequent guest programs in the question and answer as it currently is written.
In addition, we request that the following specific verbiage be added as the second to last sentence of the answer to address the subsequent utilization of the information for the same purposes at a later time be added.
"Information regarding special handling needs that has been provided under conditions (1) or (2) as listed above by customers who are not members of frequent flyer or frequent guest programs may be stored by the airline or hotel company for a reasonable timeframe. This stored information may be used to provide services for reservations made subsequent to the initial request."
If you have any questions or need additional information please contact me.
Regards,
Chris Zoladz
Vice President, Information Protection
Marriott International, Inc.
10400 Fernwood Road, Dept. #52.923.26
Bethesda, MD 20817
301/380-4094
chris.zoladz@marriott.com