The AKC, Your Privacy, and Their Legislative Agenda - Is Nothing Sacred?

The Timeline

On or about June 27th, club corresponding secretaries received a packet from the American Kennel Club that included the following letter from Executive Secretary Jim Crowley dated June 7th:

Dear Corresponding Secretary,

Our records indicate that we do not have an up-to-date, computerized list of your club's individual membership on file. AKC requests that all member and licensed clubs provide a list of their membership on an annual basis. The purpose of this is not only for approval of Events, but also to ensure that AKC maintains active communication with the greater dog fancy about issues that affect all those who breed, exhibit, judge, or simply share their lives with dogs. Today's climate of anti-dog legislation demands that we remain poised to act, educate and communicate in the interest of our sport and our dogs.

AKC will accept club lists in any electronic format, such as Excel or Access. (No paper, please. Storage and environmental considerations make the collection of paper lists less feasible than computerized documents.) Please forward information to Michael Liosis via e-mail at mal@akc.org or on disk to The American Kennel Club, Club Relations Department 260 Madison Avenue, New York, NY 10016. Please include a contact name and phone number with your correspondence.

In the future, you will be asked to provide updated membership lists in electronic format at the same time you indicate new officers in AKC records. Please keep in mind this is a necessary step in the Event Application process.

Because dogs can't speak for themselves, we have to speak for them. And we must work as a community to make our voice heard. Your participation in this effort will help the American Kennel Club fulfill our mission to take whatever actions necessary to protect and assure the continuation of the sport of purebred dogs.

If you have questions about how to provide a list or how it will be used, please contact Michael Liosis at mal@akc.org. Thank you for your assistance.

Sincerely,
James P Crowley
Executive Secretary
Cc: Club President, Club Delegate

While we can appreciate the AKC's concern to have files in an environmentally conscious format, surely a pdf file would suffice to cut down on paper document management. Because data in Excel or Access is highly maniputable, and can easily be used for marketing purposes, or other manners that breach personal privacy, we looked at AKC's policy on club membership rosters.

According to AKC's website, and the publication "Forming a New Club," under Part III, AKC Accreditation, this is what is asked for:

1. An outline of the club's development and history, including a list of meetings, elections, and activities.
2. A list of "fun" matches, including dates, sites, and number of entries.
3. A list of voting (regular and household) members' names and addresses, with the letter designations "B" (Breeder) -- someone who has registered a litter within the past three years); "E" (Exhibitor) -- someone who has handled a dog at an AKC-licensed event within the past two years), If you are applying for more than one type of competition the different types of exhibitors must be designated; "DO" (interested Dog Owner) -- someone who, although not actively breeding or exhibiting, is a dog owner of an AKC registered dog and active in the club); or "J" (AKC-licensed judge). The breed of dog owned should also be indicated, as well as the year in which each person joined the club. Individual breeding and exhibiting records are not required. (Note: Performance clubs should refer to Part V of this brochure for more information).
4. A list of club officers with addresses and daytime telephone numbers.
5. The New Club Profile Form (if not previously submitted).
6. A copy of the club's constitution and bylaws. If the sample bylaws provided by AKC are closely followed, little additional work will be necessary. If state laws require additional or different language please submit a copy of the applicable statute.

   This information will be reviewed by a staff committee, and the club will be notified of its status. Upon approval, the club will be sent match applications, rule books, and (for show and obedience clubs) the AKC's Show/Obedience Trial Manual.

Nowhere does it require that these items be in an electronic format. Nor does it disclose that this information will be used for anything other than "AKC Accreditation."

Reading Mr. Crowley's June 7th letter to corresponding secretaries, you'll see that he implies otherwise, with a bit of a heavy-handed approach. He wants the data in an electronic format, and strongly suggests Access or Excel. He further suggests that it's important that "we" speak for the dogs as they cannot speak for themselves.

At this point, our radar kicked into high gear. What does AKC intend to do with club member personal information? Club rosters likely include email and full postal addresses. Would these lists be used to directly market AKC's products? Would they be rented to third parties like vacuum cleaner companies, affinity credit card services or insurance companies? Remember that club rosters are likely to also contain the breeds of dogs that an individual member owns, in addition to the number.

Or, in light of AKC's support of PAWS, would membership lists be used to solicit AKC's own legislative agenda - bypassing the legislative liaisons and legislative alert system already in place?

We decided to ask Jim Crowley, Michael Liosis, and Daisy Okas directly. Sent via email on June 29th:

Dear Mr. Crowley,

I am writing in regards to your recent correspondence to member and licensed club secretaries soliciting lists of individual membership details. In your letter dated June 7, 2005, you state that these lists must be "computerized," and further suggest that they be in Excel or Access format. At this stage, the Dog Federation of Wisconsin must inquire as to the AKC's intentions for use of this highly maniputable data, particularly in light of an absence of concern for each club's own privacy policy, and your absence of reminding secretaries of your minimum requirements as spelled out in your publication "How to Form an AKC-Accredited Dog Club."

Specifically, can you please address the following questions:

• Should these membership lists inadvertently include contact information exceeding your requirements, will AKC expunge the excess material?
• Should these lists contain email addresses, are club members then considered "opted-in" to any electronic mailing list?
• Does AKC have any intentions of using this list for legislative lobbying of your position on legislation, such as SB1139, or direct marketing of any AKC or affiliate services?
• Does AKC have intentions of selling, trading, sharing membership information for legislative lobbying or marketing purposes?
• Does AKC have intentions of selling, trading, sharing membership information with third party organizations that are not motivated by ensuring the best interests of the organized dog fancy?

We appreciate your prompt attention to these questions, and look forward to being able to advise our own member clubs as to a suitable response.

Sincerely,

Kelly Wichman
President, Dog Federation of Wisconsin
www.dfow.org

Wxxxx Cty RD xx
xxxxx, WI xxxxx
(xxx) xxx-xxxx

We received two answers to our query. One was an email from summer intern Emily Bisso on July 8th:

Dear Ms. Wichman,
Recently we requested that electronic membership lists be sent to AKC via e-mail. We are in the process of developing a system to resume and update an abandoned method of collecting membership lists on paper and converting the information into a database. The new method will eliminate paper waste and labor costs while improving efficiencies. Most importantly, electronic lists will afford us a means to communicate with members of AKC clubs on an individual basis in instances where immediate action may be necessary, such as legislation or emergency alerts. AKC does not rent or sell membership lists to any third party.

Thank you for your assistance with this project.
Emily Bisso
AKC NY

The other, and by far more telling, answer had already reached us on July 7th:

From: "AKC Communications" <COMMUNICATIONS@akc.org>
To: "AKC Communications" <COMMUNICATIONS@smtp.akc.org>
Sent: Thursday, July 07, 2005 2:18 PM
Subject: Letter from AKC Regarding PAWS Legislation

Attached you will find a letter from our Chairman and President regarding the recently proposed Pet Animal Welfare Statute of 2005.

If you can not open the attachment, please click on the following link http://www.akc.org/pdfs/press_center/PAWS_letter.pdf

Regards,
Lisa Peterson
Director of Club Communications
American Kennel Club
260 Madison Avenue
New York, NY 10016
p: 212-696-8360
f: 212-696-8345

This "PAWS letter" also known as the "Dear Dog Lover letter," was sent to AKC club officers, delegates, and trial secretaries, at minimum. It is a sales pitch for PAWS. The method of circulation circumvented both AKC's own legislative alert system, and their legislative department's private communications to appointed legislative liaisons.

Here, we have a compelling conflict of interest between the AKC recognized Federations, the majority of which OPPOSE PAWS, and AKC's own legislative agenda. In this instance AKC has chosen to use club membership rosters to solicit their own stance, in spite of known club or federation opposition.

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