Financial Privacy Notice: Does it cover web sites? What about "cookies"?
by Sam Ott BIO AND CONTACT INFO
QUESTION: The more I read about the annual Financial Privacy Notice the more confused I get! If my bank has a Web site, does my initial and annual privacy notice also have to contain info on (i.e.) "cookies"?
ANSWER: Neither the Gramm-Leach Bliley Act or the Privacy Rule require a financial institution to specifically indicate in its initial or annual privacy notices that it collects nonpublic personal information from a consumer or customer who visits the institution's Web site. Section ____.3(o)(2)(F) of the Rule does indicate that information collected by an institution through a "cookie" is covered by the Rule. The Regulators' comments, published in the Federal Register in conjunction with the Rule, state it was not the intent to require an institution to publish a lengthy disclosure that identified with precision every type of information collected but rather provide consumers with a general description of the institution's privacy policies and practice. Each institution is given the flexibility to design its own notices. If you wish to disclose in the notices that information is collected using the "cookie" you may do so, but it also could be covered in the general description of the categories of information collected.
First published on BankersOnline.com 3/5/01
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