Skip to content
BOL Conferences Top Gun 23
Learn More - Click Here!

Thread Options
#2153274 - 11/13/17 06:34 PM Privacy Policy
Carter'sMom Offline
Junior Member
Joined: Aug 2015
Posts: 38
Do most banks have a formal privacy policy in addition to the privacy notice or are banks just using the wording in the notice as their policy?


Return to Top
Operations Compliance
#2153322 - 11/13/17 08:16 PM Re: Privacy Policy Carter'sMom
Monster Offline
Gold Star
Joined: Sep 2015
Posts: 493
I've seen it used both ways, but at my shop I prefer a separate policy from the notice, with the notice as an appendix.

Return to Top
#2153325 - 11/13/17 08:22 PM Re: Privacy Policy Carter'sMom
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,645
I too have seen both ways, though bigger banks seem to have a separate policy while smaller banks just use their notice. Also, many ethics policies cover privacy which could eliminate the need for a separate privacy policy.
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.

Return to Top
#2153393 - 11/14/17 12:39 PM Re: Privacy Policy Carter'sMom
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Regulation P is a relatively unimportant regulation driven by the one time distribution of a disclosure. Any policy for that topic alone would be verbose once you passed the second paragraph; i.e. it is unnecessary.

The broader topic of "Privacy" would incorporate information security and all other ways that banks can hemorrhage customer information. It would be a double edged sword; i.e. you could make a grandiose statement that could be used against you in the wrong situation. Write it if you need it, but don't over promise.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z, John Burnett