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#35928 - 10/04/02 04:17 PM Website Link Agreement
Anonymous
Unregistered

Does a Website Link Agreement (between a Financial Institution and Third-Party) need to contain a clause dealing with customer confidentiality? I am referencing to GLBA provision for vendors.

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eBanking / Technology
#35929 - 10/04/02 04:25 PM Re: Website Link Agreement
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
Are you talking about a simple link exchange, or is the third party going to have access to confidential information? If you're just putting a link on your site to another party, conspicuous notice to the web user that they are leavign your site should be sufficient.

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#35930 - 10/04/02 04:27 PM Re: Website Link Agreement
Anonymous
Unregistered

Yes talking about a simple link exchange.

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#35931 - 10/04/02 04:47 PM Re: Website Link Agreement
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,965
Galveston, TX
It may depend on where on your site the link is located. If the link is embedded in the secure portion of your website where only registered customers can access it, the other company could determine that this consumer that linked to their site from your site was an actual customer (non-public information). However if the link is in the non-secure area of your website, the linker could be anybody.
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#35932 - 10/04/02 05:38 PM Re: Website Link Agreement
Andy_Z Offline
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Posts: 27,468
On the Net
In its common form you wouldn't be providing any information if the user is just surfing. The site get info on the user such as their IP address, browser version, etc. but that isn't NPPI or indicative that they are your customer. Unless as RL noted they know the user came from a customer only area. Still, you haven't provided much data. A static URL would be the most. I don't know that anyone has opined that it would be NPPI, but I could see that it may.

In any case, if you have a written linking agreement, protecting your customers is always a good idea.

I do recommend a pop-up or some notification that informs the user that they are leaving your site and privacy/cookie policies may differ.
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