Management is considering entering into an arrangement with an eye clinic to provide an alternative method to the clinic’s customers for payment of their healthcare charges. A joint marketing brochure would be created wherein an individual may make application to the eye clinic for a bank loan. Verbiage within the application would indicate that the applicant was applying for the purpose of determining their eligibility for a bank loan through the clinic. The eye clinic would then subsequently forward the application to the bank.

From a privacy standpoint, we are a No opt-out bank. In order to conform with the privacy rules we would need to create a written joint agreement so they may market our own products or services. However, is there anything else that I need to consider? We would not have access to any medical records.

Thanking you in advance.

If you are talking about the joint marketing provisions of section .13 of the privacy rules, they apply to contracts between your institution and "one or more financial institutions". A eye clinic is not a financial institution.