We received information from our former affiliate banks, but now we are not affiliated. (We are an insurance agency and were sold). What can we do with the information we have that we received when we were an affiliate now that we are not an affiliate? (Our state law says follow GLB). For example, we have checking account numbers and credit card numbers that the former affiliates would no longer be able to give us. I think we can continue to use them for our business, but could not pass them to anyone else. (We never shared information with 3rd parties when we were affiliated).

The GLBA privacy provisions' only accomplishment is that they govern the content of a written notice which must be given to consumers. They neither prohibit nor authorize disclosures of customer information. They only give the consumer a right to know that certain disclosures are made and a right to opt out of some of them. The fact that the regulation does not address what a previous affiliate can or cannot do with previously acquired customer information is not an indication that the affiliate may continue to use it.

This should have been addressed in the terms of the agreement under which your agency was sold. If you use the information, it is your prior parent organization's opinion about whether it is appropriate that matters. Your attorney needs to be involved in any decision on your part to continue to use the information.