Our bank is changing companies we order customer checks from. The new check vendor wants us to provide them with a customer list including account numbers to make it easier for customers to place their first orders.

We have a conservative Privacy Policy where we do not share information with others other than the standard "for our everyday business purposes." Under Privacy, would providing a master list of customers to a third party check vendor fall under "for our everyday business purposes"?

I don't think we can do that, but I'd like some confirmation or opinions, please.

If they are not going to use the number for anything or direct market to your customers, then providing information to your vendor that I am sure has signed your vendor agreement that includes the appropriate GLBA considerations should really not be a problem.

you have hired a 3rd party company to be your check printer. they will be printing checks on behalf of your customers. of course providing them a listing of customer names and accounts would be beneficial, and business necessary. think about you don't provide and a customer enters their data wrong, there would be no ability for the vendor to verify the data is correct, they would just print and send out.

the bigger question becomes at what frequency you would provide, as your customer base can change daily with new accounts opened and old accounts closed.

your contract should discuss the purpose and use of the account listing.