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#144023 - 12/29/03 05:18 PM Privacy notice & internet banking
Tillie Offline
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Tillie
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Posts: 266
Per the FFIEC E-Banking IT Exam Handbook (pg A-7): "include E-banking considerations in the...privacy policy"
Does this mean a statement refering to our internet banking needs to be included in the annual privacy notice?
I thought I heard or read that it is necessary but cannot find it in the regulations or an example anywhere.

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eBanking / Technology
#144024 - 12/29/03 05:38 PM Re: Privacy notice & internet banking
Andy_Z Offline
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I used to believe that a bank should have one Privacy notice for "traditional" banking and one for "eBanking" so the traditional customers were not confused about cookies and such. Then I thought about it and if a traditional customer read it and then went online, you'd need to indicate it is different or they'd believe they already read it.

Now I believe you should keep it simple, one complete notice. And I believe it should also be in the annual notice.

Be sure to keep the hard copy and e-notices in sync.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#144025 - 12/29/03 06:12 PM Re: Privacy notice & internet banking
Tillie Offline
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Tillie
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Posts: 266
Does anyone have any sample language they could share?
We do not do the cookie thing or have any links to other sites.

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#144026 - 12/30/03 12:30 AM Re: Privacy notice & internet banking
Andy_Z Offline
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Don't reinvent the wheel. Look at any number of web sites for characteristics you like and dislike and incorporate that into your existing policy. Just be certain everything you incorporate is what you do.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#144027 - 01/09/04 02:18 PM Re: Privacy notice & internet banking
Bear Collector, CRCM Offline
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Bear Collector, CRCM
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Posts: 1,830
District of Columbia
Andy,
We have two separate notices - the one online includes all the info about "cookies" and online considerations; the paper notice does not. I understand what you mean about customers thinking they've read it, but our legal counsel already thinks our paper notice is too long. If we add in all the online disclosures, we may as well bind the thing in hard cover and sell it on amazon.com! With the recent push by congress to simplify the Privacy Notice, do you really think that including online information is the right thing to do? People who use the internet should know enough to look there for internet-specific information.
BC
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#144028 - 01/09/04 03:08 PM Re: Privacy notice & internet banking
Jokerman Offline
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Quote:

People who use the internet should know enough to look there for internet-specific information.




I don't mean to disagree, but of every member of my family that uses the internet (and we're talking about a dozen or so) I guarantee you that I'm the only one that knows a cookie doesn't mean Chips Ahoy.

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#144029 - 01/11/04 03:36 AM Re: Privacy notice & internet banking
Andy_Z Offline
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I believe the move is to make Privacy notices more manageable, understandable and functionable. If you have multiple notices, clearly indicate they are different and why.

I do believe they should be the same. That will in fact make your job easier as well, maintaining only one version. The non-Internet customer may see an Internet section and skip it on the notice. I don't believe it will invite additional questions. I do believe it will reduce potential confusion.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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