mini meeting notes

Notes on Meeting on May 10, 2017 with Consumer Data Industry Association

On May 10, 2017, I attended a meeting on behalf of NTIS with representatives of the Consumer Data Industry Association (CDIA), the Department of Commerce (DOC) and Office of Management and Budget (OMB). CDIA was represented by Eric J. Ellman, Senior Vice President, Public Policy and Legal Affairs, and Ariel Wolf, an attorney with the law firm of Venable LLP. Federal attendees were: Jasmeet K. Seehra (OMB); Peter Robbins (DOC); Asha Mathew (DOC) and myself.

CDIA requested this meeting with OMB to provide comments regarding the standard licensing agreement that NTIS requires persons certified for access to the Limited Access Death Master File (LADMF) to complete in order to obtain the LADMF subscription. At the beginning of this meeting, which lasted approximately 30-45 minutes, it was established that the session objective was to receive CDIA’s comments for understanding and evaluation. It was further established that a later response to those comments would be forthcoming once evaluated by OMB, DOC and NTIS. NTIS’s primary role was to listen for any issues relating to implementation of the LADMF Final Rule processes.

Primarily, the meeting focused on CDIA advising the attendees of the organization’s opinion that the current LADMF licensing agreement serves no unique purpose, as the use and disclosure of LADMF information is already controlled by statute and the final rule. CDIA expressed the opinion that the terms of the licensing agreement conflict with the final rule. In addition, its representatives stated that the licensing agreement’s description of authorized purposes and prohibited purposes for LADMF use was too restrictive for business use. CDIA’s representative provided a few examples of the language that the organization objects to in those sections of the licensing agreement.

It was agreed that CDIA would summarize its points in writing and that OMB, DOC and NTIS would respond to same after it had sufficient opportunity to review this summary.

Wayne Strickland

Acting Associate Director, Office of Product Mgmt & Acquisitions

FOIA Officer

U.S. Department of Commerce

National Technical Information Service

5301 Shawnee Road

Alexandria, VA 22312

Phone: (703)605-6543

Cell : (703)943-9670

Fax : (703)605-6388

[email protected]