Privacy Rules, Section 14 Exemptions, and Third-Party Providers
by Mary Beth Guard, BOL Guru
Question: Can you identify for me who are included in the Section 14 exception regarding third-party service providers under GLBA privacy rules. I am particularly interested in whether credit bureau agencies are included in this group.
Answer: The exception in subsection .14 to the GLB privacy rules permits disclosures of nonpublic personal information about your customer to nonaffiliated third parties as necessary to enforce, effect, or administer a transaction initiated by your customer. This exception would cover, for example, information sharing within a debit card, credit card or ATM network necessary to facilitate card transactions initiated by your customer. It would also permit sharing with your attorneys, appraisers, skip tracers.
Sharing with credit reporting agencies is expressly permitted under the exceptions listed in subsection .15 of the privacy rule.
The original version appeared in the March 2003 edition of the Oklahoma Bankers Association Compliance Informer.
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