GLBA agreement with third parties
by Mary Beth Guard, BOL Guru
Question: Do we have to enter into agreements with the insurance companies that our bank uses to force place flood, hazard and auto insurance on loans, that requires them to safeguard the customer information in compliance with Title V of GLBA?
Answer: The answer is yes, you should, IF those parties will have access to nonpublic personal information on your consumer customers in the course of providing their services to you. 501(b) of the Gramm-Leach-Bliley Act requires banks to exercise appropriate due
diligence in selecting and monitoring service providers, requires institutions to have agreements with service providers who have access to customer NPPI, requiring them to implement and maintain an information security program designed to meet the objectives of the information security guidelines, then those service providers must actually implement appropriate security measures
The bottom line is that you need to protect your customer’s information and ensure those you entrust with it handle it similarly.
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