There is no need to update a privacy notice because the Reg P features the same exclusion regarding the sharing of information to service an account. I have done some additional research into the rules cited above. It appears that in the update codes that we must submit to VISA/Mastercard there are codes to notify the merchant that the consumer elected not to participate in the program. The VISA code is titled "Contact Customer" advising the merchant that they must reach out to the customer to get updated information. The Mastercard rule states that specific information is available by reviewing the Automatic Billing Updater Reference Guide which is only available to member banks through the Mastercard Connect portal so I do not have access to that document.
This indicates that we have the ability to accept a customer opt-out, but I have yet to have a client or a card processor provide a specific citation from a VISA or Mastercard bulletin showing where we must proactively offer the opt-out option.
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