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Proposal Summary

Proposal Summary Section One

“IT BELONGS TO YOU!” This is the slogan and simple message which is to be the centerpiece and battle cry of the newest consumer education website, consumer advocate think tank, and true front line engine of research based change and standard setting, which the Association for Consumer Effectiveness (Hereinafter A.C.E or The Association) is to become once properly funded. The “IT BELONGS TO YOU!” slogan speaks directly to the specific topics for which the Association was formed and seeks to offer to the American Consumer as far as the education, advocacy, and research. “IT BELONGS TO YOU!”, is meant as a response to the operations of Data Brokers, the fundamental theme of the Associations mission, as well as a way of viewing the subject of the commodification of consumer information that is collected by Data Brokers. It is the Data Brokers who create, buy, and sell these “commodity information bundles” (hereinafter C.I.B.), which are the profiles of gathered and aggregated personal information of unknowing consumers, commoditized, bundled, and sold on open markets by an industry of Data Brokers, who sell the CIB’s for annual industry profits in the billions of dollars. Data Brokers are not in-of-themselves all evil and shady companies, working in the shadows created by consumer ignorance of the existence of Data Brokers and their operations. However, as a new industry built on cutting edge technology, these pioneers in the “Big Data Economy” have thus far been able to define the new landscape they expand into as they see fit. Moreover, because of their industry and technology trail-blazing they have thus far been allowed to convince any would be opponents and dissenters of their activities that the current Data Broker industry self-imposed system of “self-regulatory” bodies or associations are sufficient in protecting the rights of consumers, consumer privacy and seclusion, consumer data, appropriate harvesting of consumer data, the creation of CIB’s, and the selling of CIB’s. However, by utilizing the proprietary and owned assessment tool developed and owned exclusively by the Association for Consumer Effectiveness, appropriately named the Consumer Fairness and Transparency Index, the Association has been able to diagnose gross abuses, flagrant lacking of even the most basic consumer protections, and a lack of the forthcoming information needed by consumers to give informed consent to Data Brokers and their uses of consumer information for commercial and profit making purposes currently operating in consumer market channels. In fact, the development and use of the proprietary and owned Consumer Fairness and Transparency Index by the Association, has been extraordinarily successful thus far in defining not only how and where Data Brokers are substandard, but where those substandard Data Brokers need to improve in order to be deemed to be operating in an ethical manner, and to become consistent with the new industry standards set by the only non-government consumer side or consumer point of view association the Association for Consumer Effectiveness. The Consumer Fairness and Transparency Index is the only industry standards measurement tool to act as a road-map for improvement by Data Brokers, allow for and facilitate an effective, educated, and thoughtful choice by consumers as to whether or not they wish to: (a) Allow Data Brokers to utilize their private and personal information for the profit of Data Brokers, as (b) the consumer believes the use of that information by Data Brokers to be of benefit to the consumer. Or (c) chose a complete opt-out, or (d) some lessor combination of all choices, but with the ability to then always check for accuracy and make correction to any information maintained by any Data Broker. The Association, its goals, and the Association website, which is already broadcasting at, are extraordinarily important both currently and in the future. A second example of this is the second prong and branch of services the Association has already begun, which is the first national “Opt-Out List!” The Association believes it is unfair to ask consumers to seek out the thousands of Data Brokers, and individually ask to those Data Brokers to Opt-Out. For this reason, the Association has begun to create a Consumer Opt-out List. This list will be compiled and broadcast to the list of Data Brokers that will be constantly and increasingly growing daily. The creation of the list and its monthly delivery to Data Brokers will set another standard and be another first, which the Association will be bringing to the market. In being the non-profit consumer side company that is bringing two game changing systems and services to the market in the form of the Consumer Fairness and Transparency Index and the “National Opt-out List,” the Association is truly changing the market place, and creating a fairer market place for consumers. These systems and abilities are currently lacking in the market, and the Association is excited about bringing about these changes. To fulfill its’ duty, the Association has a duty to responsibly work with those Data Brokers seeking to exchange their current practices concerning consumer data, for the stated best practices published by the Association, and assessed and measured by the Associations proprietary Consumer Fairness and Transparency Index. Therefore, in this regard the Association does seek to be a true engine of change, as opposed to a mere unapproachable watch-dog Association that merely makes judgements, and wags fingers denigrating those companies that are willing to improve and exchange their current practices for the Associations stated best practices. Introduction to Organization and its Founder Section Two

The Association for Consumer Effectiveness is the brainchild of the Association President and founder Joel Drotts Juris Doctorate. Joel has a long history of community organizing and mobilizing, and has personally created and presided over several successful community based projects and organizations. By way of example, in 2011-2012 Joel Drotts did mobilize a community group of likeminded local activists to participate in the “I want a job!” campaign and filming project, which was produced by the community organization “The Poor Philanthropist.” The project unfortunately never reached or obtained the levels of funding required to fulfill the projects stated mission of creating local start-up businesses that would hire the willing and under-represented group of young adults located in San Francisco’s Tenderloin District, who are unemployed, but wanting full time employment. The plan was to spur the local economy with start-up small businesses by starting and supporting local small start-up business through and with Management Support, business modeling, document filing and execution, start-up process mapping and coaching, and of course (the most crucial component) funding. The idea was supposed to be local businesses, which would be capable of employing local young adults willing to work in the neighborhood, where so many adults of all ages chose not to seek out or engage in the practice of lawful employment, and are happy living on well-fare or engaging in unlawful income generation practices. Unfortunately, donating the funds for such a progressive plan of urban renewal was deemed too risky by those donors whom did inquire about the program. Even in the limited partnership model or local economy of scale “conglomerate” model proposed by Joel, as an alternative to non-profit and a plan to introduce, make attractive, realistic, and long-term investment possibilities in the project with a substantial return on investment for investors, it was impossible to find willing investors who were willing to buy into “high-risk stocks” or limited partnership interests, or trust units in a large scale business venture ran by “high-risk” individuals. Investors believed the project to be to high risk to invest in a group of enthusiastic and extremely desirous individuals whom unfortunately had little to no buy-in capital themselves to match, and to invest in neighborhood that was traditionally deemed a “high-risk” neighborhood or ghetto like San Francisco’s Tenderloin District. However, even with the failure of the project as a whole, or the failure to raise the needed capital for the project, our founder Joel Drotts did seem to come into his own. Joel was able to mobilize a group of thirty local volunteers to help produce and complete the video for the program, as well as overseeing the creation of several crowdsource funding webpages for the project. In his role as project creator and leader Joel proved himself as a leader whom is willing to do the ground work required to get such ambitious projects off the ground, as a savvy business and legal expert able to navigate the highly confusing City and State ordinances and statutes, political atmospheres, and fund raising activities required to have mastery over in order to create and operate of such organizations. The fact that Joel was able to rally around himself a large group of volunteers, whom believed in his vision for the neighborhood, does serve as a testament to both Joel’s personality and abilities as a leader. To this day Joel rightfully viewed the experience as a hard learned exercise in leadership and project management. It was these well learned lessons, Joel’s considerable web-development and research experience, his drive, his skill as a project leader, as well as his ability to not only describe his vision for the future, but his ability to get other people to see, share, and believe in his vision of that future which has allowed the Association for Consumer Effectiveness to not only come into existence but accomplish all that the Association has done thus far. On a non-existent budget and with a staff of only four part-time volunteers the Association has already built and is currently broadcasting the Association for Consumer Effectiveness website, which is of course the centerpiece, primary asset, communication tool, and primary stated goal of the Association for Consumer Effectiveness. Not only has the Association built the “living website,” found at, but under Joel’s leadership the Association has also developed and created the Consumer Fairness and Transparency Index. Aside from developing the Index, A.C.E. has utilized the Index to score or rate over ten of the most well-known Data Brokers, and posted those scores on the A.C.E. website for the general public. Moreover, A.C.E. as researched at least ten of the most well-known Data Broker websites, and extracted any “opt-out” information or procedures those Data Brokers may make available to the public. The Association then posted that “opt-out” information, instructions, and internet links (When available.) from those ten plus Data Brokers on the A.C.E. website, along with each Data Brokers Index Score, as well as researched information about those Data Brokers. Aside from already researching and reporting on over ten Data Brokers, creating the industries only consumer side rating tool and index, building and broadcasting an easy to read consumer friendly educational website, starting a consumer blog with privacy and technology being the primary subject focus, the Association has already drafted and made public its lawful charter, as well as registered with the IRS to gain its Employer Identity Number. All of which has been accomplished with a non-existent budget, a group of four part-time volunteers, and all thanks in no small part to Joel’s leadership, experience, organizational skills, as well as his seemingly endless knowledge in a plethora of relevant and needed subjects. However, Joel is no stranger to leadership roles, business, law, or the non-profit sector. Joel began his first business named Independent Home and Office Repair at the age of twenty-three. After several successful years in business for himself, Joel sold the successful home and office repair company that had four full time employees, one truck, and all appropriate tools to his second in charge at the company, and went back to college at age twenty-five. Joel quickly realized the distasted for academia that prevented his enrolling in college right out of high school had vanished, and in a short three years Joel graduated from New College of California in San Francisco, with a 3.6 GPA, and a Bachelor Degree in Humanities, with his emphasis being in Social Psychology. Enjoying his new found love of academia, research, and debate, Joel decided to continue his education upon being accepted into John F. Kennedy School of Law in Pleasant Hill. There Joel excelled at evidence, torts, contracts, Constitutional Law, as well as trial courses, winning his Moot Court Competition during his third and final year of Law School. While studying for his Juris Doctorate Joel also took Intellectual Property as one of his electives, a course he would come to rely much more heavily on later in his career. Joel graduated from JFK School of Law in 2009, and immediately went to work full time as a Wealth and Business Consultant for a Private Conservator of an estate then valued at over $15,000,000. This extraordinarily well paying and legal related job was not to last, as Joel soon fell in love and moved to Sacramento to be with his fiancé. There Joel got his first professional taste of the Non-Profit Sector as Joel helped co-found Efficient Solar Incorporated, where Joel served as company secretary, treasurer, and head of marketing, as well as one of three of the design team responsible for developing urban renewal and revitalization models and projects which were developed to accent and preserve the profitability of solar powered systems for home and business uses. Joel also helped create business models for home owners associations to double as small privately owned power companies that harnessed electricity from solar arrays placed on the homes of home owner association roof tops and assisted in the covenants for the real estate governed by home owner associations. Joel also participated and operated educational campaigns of awareness aimed at informing then in office government officials of the possibilities and current available applications for solar power caused by increasing industry improvements and advances in technology. After several years at the State Capital of California, Joel returned home to the Bay Area after his breaking off his engagement. It was at this point Joel returned to school once again for self-improvement, after realizing he was non-competitive in the job market at that time given his lack of knowledge of computer sciences. Therefore, as a student seeking self-improvement Joel enrolled in Heald College of San Francisco, which is a technology school. There Joel learned concepts of the internet, how it the internet works, data management, and how data gets not only created but used by various software programs and search engines. While in School at Heald Joel also went into business for himself selling a Mass Open On-Line Course that had a learning management system built into the software. The course created by Fligby at was the first ever gamification course in leadership for business, where the student or game player assumed the role as Operations Manager of a family owed winery in Napa Valley. The program measured and taught over thirty key leadership attributes and skills. After a dispute with the home company, which was based in Romania, about Joel’s right to be an exclusive North American Authorized Dealer, as well as ownership rights over a homebased on-line business model and marketing plan created by Joel and featuring the Fligby Product, Joel decided his company would no longer carry the Fligby product. This in turn caused the need for a major restructuring of Joel’s company, which at the time was set up as a third party retail, marketing, and leadership coaching business. Not willing to give up on himself and utilizing his new learned skills and knowledge of computers, Joel restructured his company as a website and smart phone application building company. Through his building of various websites and smart phone applications Joel soon realized that he could structure entire businesses around websites. It was at this point Joel’s business once again morphed from a website building business, into a business building business, which builds and sells complete packaged businesses that are built around websites or feature websites as the centerpiece of the prepackaged, preferred supplier negotiated, and step by step instruction complete small businesses for entrepreneurs interested in computer and website-centric homebased small businesses. The Association for Consumer Effectiveness is currently structured as a not for profit, mutual benefit, non-incorporated, registered association in accordance with Title 2 of the California Code of Regulations, sections 21904 and 21905; and Government Code section 12182; and California Corporations Code Section 21300. However, this is believed to be just a stop-gap, on the way to achieving legal 501c3 status with the Federal and State taxing agencies. “May we have the legal need to file for our 501c3 status officially!” is the Associations’ current view point on the fact that any non-profit MUST register proper 501c3 documentation upon receiving donations and/or gifts in excess of $20,000. In other words, should the amounts of donated funds reach numbers surpassing $20,000, therefore requiring 501c3 registration, the Association will gladly register as an official 501c3 not-for-profit corporation. However, until that line is crossed, the Association President Joel Drotts Esq. doesn’t want to file costly documents, only to later have to file more costly documents, which un-file the first costly documents should the Association fail to receive the badly needed donations in excess of the $20,000 required registration limit. Therefore, one can say the Association is taking a “wait and see” approach to its future, although the plans of the Association currently are to remain a viable and useful Association to consumers, government, and the Data Broker Industry as a whole in perpetuity. Problem Statement and Needs Assessment Section Three

We are writing this proposal in the hopes that most, if not all, of the projects funding will be granted for the continuation and expanding of the programs of education and advocacy for and on behalf of the consumer public, as well as a continued role for the Association as the standard setting and measuring entity which is independent and free to stand alone and on behalf of the consumer public! The immediate and most obvious beneficiaries of the program will of course be the American consumer public, who for the most part remains ignorant of the existence of Data Brokers and the activities of the Data Broker Industry. However, the secondary beneficiaries will be the Data Brokers and the Data Broker Industry itself as consumers become more cognoscente and aware of the existence of Data Brokers and their activity, as the Data Brokers will finally be able to know which consumers agree to having their data collect and which do not. In this way the Data Brokers will benefit through reduced levels of risk from lawsuits as the only consumer data they possess will slowly be that of only those consumers who have given their knowing and understanding consent to harvest their data. The social and economic implications of the successful funding and operating of the Association working towards its stated mission are truly extraordinary. The immediate business savings afforded the Data Brokers and the Data Brokers in the anticipated class action law suits for copyright and personal publicity rights violations alone will be in the millions. Moreover, as society feels safer on-line and more protected the psychological effects will help increase on-line shopping habits. At the same time the push-back felt by consumers and their demand for privacy, will more than likely start a movement in the opposite direction of the negative turn this country has taken with the passage of such laws as the Patriot Acts. Currently, there are no true private advocate groups undertaking the sort of aggressive consumer protection activities purposed by the Association, originating from a consumer side perspective. There are a great manly “false flag” associations pretending to be on the side of consumers and their privacy, but a closer look at whom created these “false flag” associations and a look at their politics and the policies they support quickly reveals a great many of these so-called consumer associations to be wolves in sheep’s clothing. In fact, the only advocate currently in the field for consumers is the Federal Trade Commission, who has been tracking and studying the rise of Data Brokers for over ten years. However, a great many of the Data Brokers fall outside the jurisdiction of the FTC, and even some still who should be under the FTC regulations and jurisdiction have been able to hoodwink and somehow Jedi-mind-trick the FTC into believing they are not under the jurisdiction of the FTC. The Fair Credit Reporting Act covers the provision of consumer data by consumer reporting agencies where it is used or expected to be used for decisions about credit, employment, insurance, housing, and similar eligibility determinations; it generally does not cover the sale of consumer data for marketing and other purposes. None the less the FTC has been watching the rise of the Data Broker industry. Even though the FTC is currently leading the charge for consumers as far as the FCRA grants it jurisdiction, there is still a great number of Data Brokers that legitimately fall outside the jurisdiction of the FTC. Those companies outside the FTC jurisdiction have thus far thrived, enjoyed, and taken advantage of the ignorance of the public as to their existence, as well as the lack of government jurisdiction over their activities. The Association for Consumer Effectiveness fills the gap, and shines a light into the dark shadows where these companies have thus far been able to operate. The only organization currently operating that comes close to the sort of thorough, industry wide, identification of all operating Data Broker operators, cataloging of each “opt-out” procedures (When and if offered), rating or scoring of their business practices for ethical best practices against our own Consumer Fairness and Transparency Index standardization and measurement tool, and then utilizing the A.C.E. website to aggregate, disseminate, and/or otherwise make known and available to the consumer public all collected and researched information on all operating data brokers is currently a company named “The Privacy Rights Clearinghouse” at However, true to their name the organization very much operates like a clearinghouse of privacy issues and information. Moreover, while the Privacy Rights Clearinghouse does have a section dedicated to informing the public about the existence of Data Brokers, it does not incorporate the thoroughness or informative extent which the Association for Consumer Effectiveness means to cover as the only entity dedicated exclusively to the issue of Data Brokers. At the same time A.C.E. was created to fulfill the one industry need, which has been stated as sorely lacking by the FTC, the GSA, Senator Rockefeller, the Rockefeller Foundation Research Report on Data Brokers, as well as The Privacy Rights Clearinghouse. That specific need is to create a center repository or hub where consumers can access all the information that Data Brokers do make available as far as links, procedures, and instructions on how to have their data removed via any “opt-out” options operating Data Brokers make available to the general public. However, this sort of repository while helpful is still a grossly unfair treatment of the American Consumer, as the amount of effort and time it would take the average consumer to individually contact Data Broker, and then suffer through each Data Brokers un-uniform and laborious required procedures to actually effectuate a true status of “opted-out” would be insurmountable and quite frankly most likely impossible. For this reason A.C.E. also created and service the industry first Notice Board of Desire to “Opt-Out!” The Notice Board of Desire to “Opt-Out!” functions exactly as the statutorily created, maintained, and obeyed “Do not call list” that was created by the Legislature in order to protect consumers from unwanted, annoying, intrusive, and harassing phone calls by bill collectors and telemarketers. While the “Notice Board” doesn’t carry any statutory power, at least currently, it does create an industry wide layer and level of liability and culpability or all Data Brokers who if face any litigation or issues over the use of a particular consumers’ data, can and will then be held “negligent per ce,” as opposed to the legal hurdle of a merited prima facia negligence case or argument should the consumers name not be found and counted on the “Notice Board.” The reason for this is obviously that once has opted to add their name to the consumer “Notice Board of Desire to “opt-out”,” the legal standard for negligence per ce or gross negligence will have been duly satisfied. This legal standard of juris prudence is “known or should have known.” Therefore, by placing their name upon the “Notice Board,” any consumer that does so effectively and legally puts the any and all Data Brokers “On Notice” of their desire to “opt-out” from having their data utilized. Therefore, should later litigation arise involving a Data Broker and a consumer involving the use of that consumers data by a Data Broker, the lawyers for the consumer will have a far lower and easier bar to hurdle on their way to filing any and all claims involving tort claims of negligence. For this reason, even though the “Notice Board” does not yet carry the power and authority as it would if it were created by an Act of Congress, the Notice Board is not without legal teeth and possibly greatly increased levels of risk from litigation for those Data Brokers who will most assuredly brazenly believe they can or should not respect the wish of any consumer to “opt-out,” who does dutifully place their name upon the “Notice Board.” Given the topography of the Data Broker Industry, the sometimes over-lapping jurisdictions, and often lack of any jurisdiction by the government at all over the activities and methods of operation undertaken by Data Brokers the need for the proprietary rating tool developed by the Association known as the Consumer Fairness and Transparency Index has never been greater, nor could the Consumer Fairness and Transparency Index and the Consumer “Notice Board” introductions been unveiled at a more pivotal time. The reason the Index and Notice Board are so important because not only is the Index first and only current accurate measurement tool by which Data Brokers operating procedures can be rated for fairness and levels of ethical behavior, but once combined with the Notice Board these two consumer mechanisms represent and are in fact real weapons of use for those consumers whom feel ever more embattled by the increasingly intrusive and personal data about them that is harvested and sold on a daily basis by the Data Broker Industry! As an independent rating entity and publisher of the first industry “Notice Board” the Association is capable of and is charged with the duty to help aid those Data Brokers who do want to become an ethically operated business and organization to do so. This is also a reflection of the vision of the Association itself, as because the Association is willing to help low scoring Data Brokers raise their level of ethical best practices it becomes clear that the Consumer Fairness and Transparency Index is not a tool meant to punish non-compliant Data Brokers, and the “Notice Board” merely a reflection of equitable distribution of time, money, and labor between Data Brokers and those consumers who are desirous of “opting-out” across the board. Together the Index and the “Notice Board” fulfill needs of a nation of consumers, as they serve as the much needed balance, possible Data Broker legal repercussions for unethical and self-serving disrespectful behavior towards consumer’s right to control their own data and say whom may use it, for what purposes, and when it may be collected. What is truly startling is the lack of true private consumer side advocacy, which is independent, stands, and speaks for the Consumer side of the Data Broker Industry issue. This is extraordinarily disturbing and worrisome, when one stops to consider and realize that Data Broker Industry currently has some of the well placed, well-funded, and well connected lobbyists in the nation, which are currently persuading and “advising” the legislature of both houses about what “they” believe to be in the best interest of American Consumers and their right to privacy. Again, the FTC has done an amazing job thus far, and the Association for Consumer Effectiveness seeks to augment and add to those efforts by filling in the gaps and holes that occur either do to jurisdictional issues or other governmental oversite shortfalls. For example the FTC cannot lobby legislatures, where as a private entity can. Moreover, the Association means to truly stand up for consumers, where a government entity can fall victim to political winds and wills. Current Consumer awareness as to the existence of Data Brokers, the Data Broker Industry, the creation of Commodity Information Bundles (CIB)’S, the buying and selling of CIB’s by various Data Brokers and retail industries, the sorts of data that a CIB may contain, the way data is collected to create CIB’s, the collection points for consumer data, as well as the frequency and extent that consumer data is harvested, is close to 2% of the internet and smartphone using public according to at least two different surveys conducted by the Association. In two separate blind surveys conducted by the Association, we asked one hundred random Americans, of various age groups, races, education levels, and socio-economic backgrounds, all of who claimed to use the internet, a smartphone, or some combination of the two on a regular daily basis if they (a) knew what Data Brokers are, (b) if they knew what Data Brokers did, and (c) if they were aware their data gets recorded and harvested beyond mere “cookies” every time they got on-line or used their smartphones? The results were shocking. Of those whom participated in the survey only 1-2% had ever heard the term Data Broker, and only 1-3% could accurately tell us what exactly Data Brokers did. Surprisingly almost 86% of those same Consumer Americans reported being aware that their data was tracked and stored every time they got on-line. However, that same 86% of Consumer Americans could not tell us how the data was collected, whom collected their data exactly, why their data was wanted, and almost all Consumer Americans were shocked to find out that it was private companies harvesting their data to sell to other companies, and not the United States Government whom monitors, collects, and stores the data generated by their on-line and smartphone use and activities. These low percentages of consumer awareness about the existence of Data Brokers, the Data Broker Industry, and the Data Broker Industries Activities are far too low. Especially when one considers that the vast majority of consumers asked stated they would chose to “opt-out,” and expressed an interest in learning exactly how they could “opt out” or otherwise exert some varying level of control over what information gets harvested and is made available to various parties of concern. Education of the public is the best defense against these Data Brokers and their activities. As the primary platform for educating and informing the public about Data Brokers and the activities of the Data Broker Industry is the Association website located at, one of the primary goals of the Association for Consumer Effectiveness is to gain national recognition and brand awareness for and about the website as quickly as possible. The reason for this should be fairly obvious, as the Association website is only useful and helpful to consumers if they visit and utilize the website. To that end consumers can or will only visit the website, to educate themselves with the information contained on the website, if they are aware that the website exists and what sorts of information can be found on the website for free. For this reason, aside from a major national advertising campaign, A.C.E. seeks to cooperate with various Parent and Teacher Associations and Groups, who can educate teenagers and possibly even junior high school students about the existence of the Association website, the information that can be found for free on the website, what exactly the Consumer Fairness and Transparency scores mean, and why they are important. By reaching the younger generations in their learning environment, and exposing them to not only the Association website but to the concept of Data Brokers and the Data Broker Industry early we can ensure that future generations of consumers are more effective and protected than the generations of consumers that came before them.

\ Project Objectives Section Four

1. Create and maintaining a free, easy to use, consumer side website, where all educational, research, and advocacy efforts are made known to the American Consumer Public for the benefit of the American Consumer Public. 2. Create and maintain the Consumer Fairness and Transparency Index Rating System for Data Broker standardization of consumer fairness and adequate privacy controls, and report those findings and/or rated scores on the Association website for the benefit of the general consumer public and Data Brokers as well. 3. Provide all helpful Links and helpful instructions on how American Consumers can “opt-out” from having their information utilized by Data Brokers. 4. Provide Reports to the general public, requesting government agencies, and/or Data Broker companies as well as to Consumer Fairness and Transparency Index findings, and ways to become “Index Compliant” and utilize standardized best practices for the handling, harvesting, and selling of consumer personal information. 5. Provide “Cliff Notes” to the lay American Consumer, for the many usually long and complicated Government Agency Source Reports, Whitepapers, and other known and respected industry insider white papers or reports on the subject matter. 6. Advocate for Consumer Privacy Controls that incorporate the ten principles and standard “need to know” points of information required by the standard American consumer, so that consumers may then tender their true knowing and willing consent to the commercialization and usage of their personal and private data by Data Brokers on-line or otherwise. 7. Achieve a national recognition of the website and the Association for Consumer Effectiveness, which will help ensure that American Consumers are aware of the Association, the existence of the Association website at, and the sorts of information that can be found for free on the Association website. 8. Become the de facto Consumer side advocate for all issue relating to Data Brokers and the Data Broker Industry. 9. Generate and create a perpetual fundraising, donation and grant receiving platform that is capable of supporting and funding all research, education, and advocacy undertakings and activities of the Association for Consumer Effectiveness. 10. Maintain and transmit to Data Brokers a national “Opt-out” list of consumers, who are desirous of “opting-out” their personal and private data.

Projects Method and/or Design Section Five

The task of maintaining the free, easy to use, consumer side website, where all educational, research, and advocacy efforts are made known to the American Consumer Public for the benefit of the American Consumer Public, shall be the responsibility of the entire full time staff. However, should funding permit the Association does seek to hire at least one full time website developer, whose primary duty shall be the maintaining of the Association website, as well as ensuring all content updates, blog postings, research papers, photos, or videos that the staff of the Association sees fit to post or make a part of the website for the beneficial knowledge of Consumer American website visitors. This individual will also have the duty of building and maintaining a smartphone application for the Association. Web Developer The web developer shall also be the designated social media presence controller. It shall therefore fall upon the holder of this position to maintain the various and several social media accounts and profiles on behalf of the Association. This shall include responding to blogs, texts, tweets, or other social media interactions on behalf of the Association. This is crucial and important so as to give the consumer public the impression and feeling that the Association is a living and responsive entity that is seeking to engage with the public at all times. Research Staff: Opt-out Director The task of maintaining the Consumer Fairness and Transparency Index Rating System for Data Broker standardization of consumer fairness and adequate privacy controls, and report those findings and/or rated scores on the Association website for the benefit of the general consumer public and Data Brokers as well, shall fall upon a team of two researchers whose duties it shall be to maintain the Index, seek out new and as of yet unrated Data Broker companies, research those companies for any and all consumer “opt-out” links and instructions, fairly rate those companies according to the Consumer Fairness and Transparency Index, report their findings and research to the webmaster for inclusion in the Data Brokers section of the website. Research Staff: Index Director Furthermore, this team shall provide all helpful Links and helpful instructions on how American Consumers can “opt-out” from having their information utilized by Data Brokers. Moreover, the research team shall submit their findings to the rated Data Broker companies, along with suggestions upon how to become compliant, and work with any willing Data Broker Company to help said willing and wanting data broker company to become compliant with the Index. In addition to the aforementioned research and vetting activities, the research team shall remain abreast of all current issues, trends, laws, bill proposals, read whenever possible as many whitepapers and reports on the subject of merit and worth, and digest those learned treatise into more user friendly, shortened, and condensed “Cliff Notes,” for inclusion on the website for the reading and education of lay American Consumer website visitors. Marketing The Association shall at all times employ a marketing and advertising specialist whose job it shall be to supervise the Associations media advertisement spend, and ensure the Association achieves a national recognition of the website and the Association for Consumer Effectiveness, which will help ensure that American Consumers are aware of the Association, the existence of the Association website at, and the sorts of information that can be found for free on the Association website. Fundraising The Association shall have employed a full time fundraising and grant writing expert, whose duties shall include any and all fundraising, donation and grant gaining, and all other activities that lead to the generating of income or funds for the Association, so the Association may pay its personnel, advertise its existence, and continue to carry on its stated activities and goals. This person shall have the ability to use the Association name, brand, and sell advertisement space on the website, as well as organize fund raising activities. Director The Association shall have at all times a President or Director whose duties shall be the overseeing and management of all other employees and their activities and/or duties. To hire and fire any and all employees, all of who serve at the pleasure of the Director. The Director also has the duty to set policy, and oversee the performance of all employees and their duties. The President/Director shall also aid any and all employees in their assigned duties, as well as act as the chief spokesperson for all matters that directly involve the operations of the Association. The Director alone may also hire as needed payroll or accounting professionals, legal professionals, and oversee the financial viability of the Association as well as all day to day operations and activities.

Organizational Flow Chart of Positions and Authority. Section Six


Organizational Needs Assessment Section Seven

Stated Goal The Association’s fundamental two mission goals are education and advocacy for the American Consumer Public, about the existence of Data Brokers, the Data Broker Industry, and the harmful Activities of the Data Broker Industry. To that end the Association broadcasts the website in order to act as and become the central repository and portal of accessible information for consumers concerning Data Brokers, in order that consumers may become educated. In so doing, the Association is helping consumers to become more effective and proactive in defending their private information from unlawful and unethical abuses of their data by Data Brokers. Aside from housing and offering the information deployed on the website, keeping the as the primary consumer contact and communication point as the website, we have incorporated on the website all the links and instructions made available by Data Brokers, and incorporated our advocacy systems. The advocacy systems the Association has deployed are the Consumer Fairness and Transparency Index, as well as establishing the industry first “Do not track list.” The advocacy systems enable consumers to better protect themselves and their information, by empowering the Association as their advocate and researcher into the Data Broker Industry Strategic Plan of Action Marketing With the goals of the Association clearly stated and laid out, what then are the needs of the Association which will help ensure the Association not only reaches its goal, but maintains those goals hopefully in perpetuity? The Association has a three pronged mobilization of work flow, designed to fulfill the two mission goals of education and advocacy for the American Consumer Public. The first and overarching need is to acquire the funds to mount an all-out multi-platform, nation-wide, media advertisement campaign, designed to deliver one simple theme, “We exist, we’re here for you, Data Brokers exist and are harming you, and if you want to find out how and what to do about it check out” Once the Association is fully funded, staffed, located, and underway both the ROI of the ad-spend and the over-all progress of the Association can and will be easily and successfully measured and articulated by the number of website hits the Association receives, as well as its conversion rate. The conversion shall be considered any time a consumer adds their name to the “opt-out” list. In this way our growth and success are uniquely tied to these numbers, as the stated mission of the Association is the education of the public and advocacy of the public. In this regard, by informing Data Brokers of the names of consumers found on the “opt-out” list, we are directly advocating for the consumer public as well! Even though Joel and his part-time volunteer team of four were able to accomplish what amounts to a non-profit business miracle, by creating and building out the “proof of concept” fully functional Association website, along with all its trademarked and proprietary systems, indexes, research, as well as drafting to completion this grant proposal, all ahead of the stated and set time horizon for completion, and with a budget of only $450.00, the Association cannot and will not survive with the addition of dedicated full-time paid employees. Therefore, the diagram above is a representation of the absolute most bare bones operational organization structure required, in order to realistically operate and maintain the Association for five years, fulfill and complete all the Association stated goals, handle any and all communication responsibilities, and represents the absolute least amount of required full-time dedicated staffing levels the Association must be able to fund through government and private grants, donations, and/or any and all fundraising activities. Advocacy The proper funding of a full time staff will allow the Association to fulfill both the advocacy and education goals. The two primary researchers are the keys to the envisioned workflow management, as the primary team producing and facilitating the actual “product” or services the Association plans to offer the consumer public. By having a two person research staff, one team member shall be dedicated strictly to the management of the “Do not track” list. This researcher will be responsible for maintaining the list and communicating the do not track list to Data Brokers. Furthermore, this researcher is expected to stay abreast of any and all laws about “Do not track lists,” as well as producing advocacy articles on the subject. Education The second researcher will handle the vetting of Data Brokers and the Consumer Fairness and Transparency Index. This position has the responsibility of seeking out all known and new Data Broker companies, and then vetting those companies against the Consumer Fairness and Transparency Index. This position is also responsible for locating the “Opt-out” links and instructions from the website of every new Data Broker company. This position is also expected to produce articles on the subject, and work with any and all Data Brokers whom may decide to become compliant or improve their score on the Index, by adopting the best practices and standards that are set and measured by the Index. Both research positions will be extraordinarily unique and busy positions, given the number of Data Brokers, and the amounts of detail and services the Association means to offer consumers. As stated the two researchers produce the “products” of the Association as far as education and advocacy, and the marketing department is tasked with ensuring that the Association has a large enough audience of consumers to actually help the general public. The three departments or prongs of the Association represent the primary activities of the Association, and the remaining departments or position essentially exist in order to support and aid the three primary positions in fulfilling their goals. The remaining departments do this by raising the funds via grants, donations, and fundraising activities, handling the website maintenance, as well as the over-all management and operation of the organization as a whole. The diagram above shows the absolute bare minimum staffing levels, and positions needed in order to successfully complete the stated mission of the Association. Operational Costs Section Eight

Stated Costs YEAR ONE YEAR TWO YEAR THREE Salary for annual staffing minimums. 240,060 240,060 240,060 Rent (Location in San Francisco Bay Area) $5,000 MONTHLY 12 MONTHS YR. TOTAL: $60,000 $60,000 $60,000 Phones, computers, office furniture $20,000 $0.00 $0.00 Marketing Costs Nationwide. $100,000 $150,000 $200,000 Misc. Operating Expenses (Electricity, internet, Legal, Accountant, janitorial, other) $100,000 $100,000 $100,000 TOTAL $520,060 $500,060 $500,060 The Association currently has no infrastructure beyond the proof of concept website. There are no facilities, no computers, no phones, and no offices, all of which are needed in order to create and operate the Association of a regular and full time basis. These costs shall be one-time only start-up fees. Fundraising Section Nine The fundraising and marketing team or experts shall work hand in hand to utilize the media spend budget. The reason being the Association needs to communicate not only that it exists; offers the services it does, but also inform the public that it needs donations to survive. It is the plan and desire of the Association to offer its services to the public for free, as the consumer public has already been taken advantage of by the Data Brokers. It is contemplated that memberships which offer receiving a news-letter that contains the latest research from the Association in article for about privacy and the state of the Data Broker Industry. With this effort, it is believed that after the first year of full operation the Association shall be able to be self-sustaining through the donations, continued grant seeking, membership sales, and other fundraising activities. These efforts shall hopefully be aided by gaining celebrity spokes people. The causes that the Association is advancing are directly aligned with the ability of the entertainment industries ability to earn continued profit, as such it is believed receiving or finding celebrities to help advance the cause won’t require great efforts. Once celebrity or celebrity’s spokes people or name affiliation helps raise awareness and brand recognition, it is believed that donations and grant receiving shall also become easier as well.

Organization Bench Marks Section Ten 1. Creating the team 2. Building a website 3. Writing a Grant 4. Receiving a Grant 5. Producing a business and operating plan 6. Securing a facility and furniture 7. Hiring required staff 8. Begin operations 9. Gaining one million conversions 10. Gaining ten million conversions Organizational Evaluation Section Eleven

As a non-profit the organization stands in a unique position when it comes to the analysis of the business and operational outcomes, or more commonly described as the return on investment. It is agreed and understood that in the non-profit field the larger the audience served, than so too is the market and population upon which the organization can seek and ultimately receive donations from. To this end, it is both a proper measurement and analysis tool to measure the brand recognition of the organization. In order to achieve this analysis the following formula shall be utilized in judging the media add spend (Sample size of target marketing demographic) – (Original sample size of target marketing demographic) = (Increased consumer familiarity of products or service) / ($ spent for time period which one engages in active social media advertising campaign) < ($ of donations realized cover the cost of said campaign, with realized increased gross over-all donations.)} [©Joel Drotts 2013]. In order to gain the numbers for the above analysis the Association shall use the number of sign ups, the number of views to the website, as well as conducting random polls of the population to find who has heard of the Association. At such point as the realized donations is greater than the formula equation to the left of the greater than symbol above the Association shall be considered to be running at peak performance. As the bulk of the organizations advertisement will be through on-line campaign the organization will have access to a great deal of analysis tools, which will allow the director to make the proper adjustments to operations and spending to levels that will allow the Association to continue to operate, self-funded through donations, advertisement on the Association website, membership sales, as well as receiving grants.

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