New Privacy Regs: Exempted Nonaffiliated Third Parties
Lucy Griffin and Linda Westfall, BOL Gurus Guru Bio
QUESTION: I would like to confirm that the following companies are exempted nonaffiliated third parties under the new privacy regulations. My bank is a small community bank with no affiliates. Companies: Dunn and Bradstreet and TransUnion (business and consumer credit reports), Deluxe (check printing), ChexSystems (consumer DDA bad checks), and MasterCard/NYCE (credit/debit cards).
ANSWER by Lucy Griffin BIO AND CONTACT INFO
Yes. These are all companies that are either credit reporters or third party business partners. As such, they are subject to the exemptions of the privacy regulations. However, you should still have provisions in your contracts with them that require them to protect the privacy of your customers.
ANSWER by Linda Westfall BIO AND CONTACT INFO
In my opinion, these companies would fall under the .14 exemption. This section of the regulation exempts disclosure of customer information from the notice and opt out when the disclosure is "necessary to effect, administer, or enforce a transaction".
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