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1
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EXHIBITS A-E
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EXTRACTED KEY WORDS
STUDENTS SURVEY SCHOOL EDUCATION AMERICA REPORT EXHIBIT ARTS SCIENCE ERCA HIGH SCHOOL RESERVATION TEACHER ENGINEERING CHRISTIAN TECHNOLOGY COMMUNITY COMPLETED SURVEYS ANNUAL SURVEY DESIGN CHURCH UTILIZE ADMINISTER COOPERATION GOALS COMPILE PHYSICIAN MANAGEMENT BUSINESS |
EXHIBIT A
,
Educational Research Center Of America
ERCA is a non-profit corporation that
conducts a voluntary survey of high school
students throughout the United States. The
survey is designed to help students
their education and professional
development by enabling institutions of
higher learning to identify potential
and to provide them with information
curricula, extracurricular activities and
financial aid programs. The ERCA survey
results are available free of charge, on
ERCA web site. ERCA will also provide a
minimum of 25 scholarships per year to
deserving students. Participation in the
survey is not a prerequisite to receiving
ERCA scholarship.
ERCA's Privacv of Student Information
Exhibit A
http://www.studentresearch.org/public/index.html
EXHIBIT B
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2
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AGREEMENT CONTAINING CONSENT
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EXTRACTED KEY WORDS
IDENTIFIABLE INFORMATION COMMISSION STUDENT COMPLAINT MARKETING EDUCATION PROPOSED RESPONDENTS OFFICER FEDERAL TRADE DISCLOSURE PURPOSE STUMACHER AGREEMENT MARIAN SANJANA COMMUNICATIONS ERCA BUSINESS EDUCATIONAL RESEARCH AMERICA SMG DRAFT COMPLAINT STUDENT MARKETING GROUP CONSUMER NONEDUCATIONAL-RELATED MARKETING PURPOSE SUCCESSORS SURVEY ACCEPTANCE PRINCIPAL OFFICE COUNSEL |
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In the Matter of
EDUCATIONAL RESEARCH CENTER OF AMERICA, INC., and
STUDENT MARKETING GROUP, INC., corporations, and
MARIAN SANJANA, individually and as an officer of
EDUCATIONAL RESEARCH CENTER OF AMERICA, INC., and
JAN STUMACHER, individually and as an officer of
STUDENT MARKETING GROUP, INC.
FILE NO. 022-3249
AGREEMENT CONTAINING
CONSENT ORDER
The Federal Trade Commission has conducted an investigation of certain
acts and practices of Educational Research Center of America, Inc. and
Student Marketing Group, Inc., corporations; Marian Sanjana,
individually and as an officer of Educational Research Center of
America, Inc.; and Jan Stumacher, individually and as an officer of
Student Marketing Group, Inc. ("proposed respondents"). Proposed
respondents, having been represented by counsel, are willing to enter
into an agreement containing a consent order resolving the allegations
contained in the attached draft complaint. Therefore,
IT IS HEREBY AGREED by and between Educational Research Center of
America, Inc. and Student Marketing Group, Inc., by their duly
authorized officers, and Marian Sanjana and Jan Stumacher and counsel
for the Federal Trade Commission that:
1. Proposed respondent Educational Research Center of America, Inc.
("ERCA") is a Pennsylvania corporation with its principal office or
place of business headquartered in Pittsburgh, Pennsylvania.
2. Proposed respondent Marian Sanjana is an officer of ERCA. Her
principal office or place of business is the same as that of ERCA.
3. Proposed respondent Student Marketing Group, Inc. ("SMG") is a New
York corporation with its principal office or place of business at 300
Merrick Road, Suite 206, Lynbrook, New York 11563.
4. Proposed respondent Jan Stumacher is an officer and director of
SMG. His principal office or place of business is the same as that of
SMG.
5. Proposed respondents admit all the jurisdictional facts set forth
in the draft complaint.
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3
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COMPLAINT
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EXTRACTED KEY WORDS
SURVEY HIGH SCHOOL RESPONDENTS EDUCATION MARKETING OFFICER ACTS COLLEGES ERCA JUNIOR HIGH SCHOOL FEDERAL TRADE COMMISSION PRACTICES COMMERCE SMG EDUCATIONAL RESEARCH AMERICA SURVEY REPORT EXHIBIT PERSONAL INFORMATION COMPLAINT BUSINESS ALLEGES STUDENT MARKETING GROUP TRENDS PRIVACY STATEMENTS COMPILE SURVEY DATA PRINCIPAL OFFICE REPRESENTATION |
0223249
UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
In the Matter of
EDUCATIONAL RESEARCH CENTER OF AMERICA, INC., and
STUDENT MARKETING GROUP, INC., corporations, and
MARIAN SANJANA, individually and as an officer of
EDUCATIONAL RESEARCH CENTER OF AMERICA, INC., and
JAN STUMACHER, individually and as an officer of
STUDENT MARKETING GROUP, INC.
DOCKET NO. C-
COMPLAINT
The Federal Trade Commission, having reason to believe that
Educational Research Center of America, Inc. and Student Marketing
Group, Inc., corporations; Marian Sanjana, individually and as an
officer of Educational Research Center of America, Inc.; and Jan
Stumacher, individually and as an officer of Student Marketing Group,
Inc. ("respondents"), have violated the provisions of the Federal
Trade Commission Act, and it appearing to the Commission that this
proceeding is in the public interest, alleges:
1. Respondent Educational Research Center of America, Inc. ("ERCA") is
a Pennsylvania corporation with its principal office or place of
business headquartered in Pittsburgh, Pennsylvania.
2. Respondent Marian Sanjana is an officer and director of ERCA.
Individually or in concert with others, she formulates, directs,
controls, or participates in the policies, acts, or practices of ERCA,
including the acts or practices alleged in this complaint. Her
principal office or place of business is the same as that of ERCA.
3. Respondent Student Marketing Group, Inc. ("SMG") is a New York
corporation with its principal office or place of business at 300
Merrick Road, Suite 206, Lynbrook, New York 11563. SMG also does
business as the College Bound Selection Service.
4. Respondent Jan Stumacher is an officer and director of SMG.
Individually or in concert with others, he formulates, directs,
controls, or participates in the policies, acts, or practices of SMG,
including the acts or practices alleged in this complaint. His
principal office or place of business is the same as that of SMG.
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4
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ANALYSIS
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EXTRACTED KEY WORDS
SURVEY MARKETING MARKETING PURPOSE PROPOSED RESPONDENTS EDUCATION DISCLOSING HIGH SCHOOL COLLEGES AGREEMENT CONSENT ORDER NONEDUCATIONAL-RELATED MARKETING PURPOSE COMPLAINT SURVEY REPORTS COMMERCIAL ENTITIES RECRUITMENT SMG COMPILES JUNIOR HIGH LIST BROKER COMMISSION PROVISION CONNECTION ALLEGES DETAILING PUBLIC RECORD ERCA OFFICER ACCEPTANCE STUMACHER |
Analysis of Proposed Consent Order to Aid Public Comment
In the Matter of
Educational Research Center of America, Inc.,
Student Marketing Group, Inc.,
Marian Sanjana, and Jan Stumacher
File No. 022-3249
The Federal Trade Commission has accepted an agreement, subject to
final approval, to a proposed consent order from Educational Research
Center of America, Inc., ("ERCA") and its officer Marian Sanjana
("Sanjana"), and Student Marketing Group, Inc., ("SMG") and its
officer Jan Stumacher ("Stumacher"). ERCA is a student survey company
that provides student data, through SMG, to colleges and universities
and other entities for recruitment and marketing purposes. SMG is a
commercial list broker that supplies names for youth marketing
campaigns.
The proposed consent order has been placed on the public record for
thirty (30) days for receipt of comments by interested persons.
Comments received during this period will become part of the public
record. After thirty (30) days, the Commission will again review the
agreement and the comments received and will decide whether it should
withdraw from the agreement and take other appropriate action or make
final the agreement's proposed order.
This matter concerns representations about how detailed, personal
information collected from middle, junior high, and high school
students through a survey would be used. The proposed respondents
distribute a survey to middle, junior high, and high school teachers
and guidance counselors with the request that they have their students
complete the survey. The survey collects from students personal
information including name, address, age, race, religious affiliation,
and academic, career, and athletic interests. ERCA compiles personal
information collected from high school students into a survey report
that it provides to colleges and universities. It also provides
personal information collected through the survey to SMG. SMG provides
the survey information to colleges and universities, and also creates
lists of students that it provides to commercial entities for use in
marketing. Such entities include, but are not limited to, banks,
insurance companies, consumer goods and services providers, and list
brokers.
The Commission's complaint charges that the proposed respondents
falsely represented that information collected from students through
the survey is shared only with colleges, universities, and other
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