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#2280352 - 01/26/23 09:55 PM Privacy Policy Update
dtew Offline
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Joined: Apr 2021
Posts: 15
We have to revise the Bank's Privacy Policy prior to March 1st due to a requirement of Google. If we don't meet this deadline, Google will remove our business and consumer Mobile Banking apps from the App Store. How much time do we have before the effective date to mail updated Privacy Policies to all customers? I want to say 30 days, but I can't find that anywhere. This must be mailed, right? Unless they can acknowledge they received it electronically?

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General Discussion
#2280354 - 01/26/23 10:41 PM Re: Privacy Policy Update dtew
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Have you read 1016.8? What change are you going to be required to make? You mean to your Mobile Banking agreement or your actual bank privacy policy?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2280448 - 01/30/23 03:33 PM Re: Privacy Policy Update dtew
KMenard Offline
Member
Joined: Oct 2014
Posts: 77
Google is requiring the Bank to add a "Mobile Privacy Disclosure" statement to our Privacy Policy notice. The Mobile Privacy Disclosure statement lets the customer know that "the mobile application will request access to information stored on the customer's device such as their location, camera, contacts, or other features to enrich and simplify their experience and improve our services." It goes on to state that "Before granting access to this information, you will be prompted to give the application that permission; if you do not wish to grant that permission, you may decline; and if you later change your mind, those permission can be updated in you device's setting"
Google is requiring the Bank update the policy by 3/1/2023. How far in advance would we need to notify our customers, 30 days? Or can we wait until the annual mailing in June?

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#2280488 - 01/31/23 02:19 PM Re: Privacy Policy Update dtew
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
You allow your on-line banking application to be hosted by a third party that will then have " access to information stored on the customer's device such as their location, camera, contacts, or other features "?

If that is the case, then why is this suddenly an issue. You mean you have been allowing this to happen all along and not telling your customers?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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