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#2153274 - 11/13/17 06:34 PM Privacy Policy
Carter'sMom Offline
Junior Member
Joined: Aug 2015
Posts: 37
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?


Thanks!

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#2153322 - 11/13/17 08:16 PM Re: Privacy Policy Carter'sMom
Monster Offline
Gold Star
Joined: Sep 2015
Posts: 453
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.

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#2153325 - 11/13/17 08:22 PM Re: Privacy Policy Carter'sMom
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,587
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.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#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.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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