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#1701180 - 05/18/12 05:00 PM Privacy Opt-Out vs Joint Marketing
Compliance Poster Offline
Gold Star
Joined: Sep 2001
Posts: 422
If an institution wishes to market an ID protection account-add-on product of a third-party to its existing customers, and provide nonpublic personal information of its customers to that same third-party to do the marketing, does this fall under the joint marketing exception or is a privacy notice with an opt-out required?

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Operations Compliance
#1701422 - 05/18/12 08:55 PM Re: Privacy Opt-Out vs Joint Marketing Compliance Poster
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,923
Galveston, TX
I'm not sure how you could get this product to fall under a joint marketing agreement?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1701502 - 05/21/12 11:25 AM Re: Privacy Opt-Out vs Joint Marketing rlcarey
Compliance Poster Offline
Gold Star
Joined: Sep 2001
Posts: 422
Randy,
I was thinking that since it is not the bank's product and it is being marketed by the third-party, there needs to be an privacy opt-out provided to all the customers of whom will be solicited. Are you thinking the same thing?

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#1701878 - 05/21/12 11:44 PM Re: Privacy Opt-Out vs Joint Marketing Compliance Poster
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,923
Galveston, TX
If you can't get it to fall into one of the exceptions, then an opt-out is needed.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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