I have a deposit customer with an active account who wants to add a name to the account a year after the account was opened.Must we provide an initial privacy notice to the secondary name that is being added? What is the secondary name being added lives at a different address?

You might think you are adding a person, but in reality, you are just opening a joint account with the same account number - give them all disclosures.

And don't forget that, unless the new joint owner already has an account with you, this is a CIP trigger.