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Website Privacy Policies
by Richard Insley, BOL Guru
BIO AND CONTACT INFO
QUESTION: Is it a requirement to have a privacy policy posted on a website, when the website is simply a "presence" and the bank does not collect any information and permit customer transactions?
ANSWER: No, although it's a good idea (strongly recommended by regulators), you are not REQUIRED to post a privacy policy on an information-only website to comply with the GLB regs. As the site grows in sophistication, however, you need to reassess this decission. If you add application forms that allow surfers to become "consumers" or "customers" then your GLB disclosure responsibilities increase. Nevertheless, you may still be able to use paper disclosures to meet these responsibilities--so long as the paper reaches the customer in a timely fashion.
First published on BankersOnline.com 1/7/02
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