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#1662372 - 02/08/12 09:49 PM Privacy Question
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Sorry - long story to get to a quick question -

I'm talking with a non-profit who works with single parent (mother's only) families who need help getting back on their feet. This non-profit helps the mother's get back on their feet through a variety of programs, etc....
They currently require the mother's to put XX% in to savings to teach them good savings habits.
The group has approached us about offering a checking/savings program to the mother's - the group would like to have access to the mother's accounts (as a requirement of their program) to view and monitor only - they do NOT want access to the funds. I'm thinking that if we have the mother's sign a release allowing us to create a user profile for the case manager's to view their accounts we would be ok.

However, I know there's a wealth of backgrounds and information here on BOL, so wanted to see if there's anything I have missed, and/or might want to consider....

Thanks
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#1662561 - 02/09/12 03:00 PM Re: Privacy Question RBanker
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
R Banker-

I would agree for the most part. I also think you should do a bit more... and even this might not save you from a regulator should they be very well versed in privacy rules.

My additional suggestions:

Depending on the number of customers who have this set up this way... I would make sure I "audit" user activity on a monthly basis to make sure that the rights are established correctly and that they aren't prying (looking to regularly) into the account information. I would also see if my system allows for an account number to be masked while on the system... (BofA does, and it takes a few mouse clicks to get to an unmasked number). Also see if for these accounts you can suspend the ability to view documents (check images and statements) for users with view-only access. To me its not so much that view only is a transactional problem, but that customer information can be compromised, even with "permission". So get the non-profit to establish a control program so that even their logins and people with access to the customer accounts is very detailed and controlled.

I would also get a reaffirmation of the customers desire to have the non-profit looking at their account on at least a bi-annual basis.

Lastly, I would have a plan in place to make sure you know when a customer no longer works with or is guided by the non-profit so that you can immediately suspend view only rights.

Cheers!
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#1662586 - 02/09/12 03:41 PM Re: Privacy Question RBanker
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Could the ladies simply ask for a duplicate statement to be mailed directly to the organization? This would remove the bank from a potentially volatile situation and simplify the process considerably.
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#1662601 - 02/09/12 03:54 PM Re: Privacy Question RBanker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
That's a lot better idea. I doubt that this group is going to find any bank that is going to be willing to allow the set-up of on-line third party inquiry access for a few accounts.
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#1662993 - 02/09/12 08:51 PM Re: Privacy Question RBanker
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
BrendaC,
I really like your idea and that might work.

(See, it's good to brainstorm....)
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#1663229 - 02/10/12 02:22 PM Re: Privacy Question RBanker
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
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R. Banker,

Just make sure you have a mechanism to stop sending once the women have stopped participating in the program or what have you...
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In life, there is a lot less that could get better and a lot more that could get worse.

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My views only!

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#1663830 - 02/10/12 11:00 PM Re: Privacy Question RBanker
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Yep, already covered that - as part of their exit checklist. Thanks
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