We are preparing to contract with a 3rd party vendor to perform a service for us that is covered under one of the Reg P exceptions. (premissible sharing of client information). In their contract, this vendor has stated that they will not rent, sell or share any of our client non-public persona information, but they do reserve the right to contact our clients themselves to perform surveys to ensure that our clients are happy with the services the vendor provides.
Do any of you have an opinion about whether this is a permissble activity under Reg P? This vendor will not be "selling" anything - just ensuring that our clients are satisfied.
Is this a problem?
Thanks in advance for your input.
Leslie

I just don't see how it would be a problem, since you will be disclosing the relationship to your customers. It probably would be good to include the fact that customers may be contacted from time to time only for customer satisfaction surveys. Disclosure to the primary element, so that customers can opt out if that type of contact is unwanted.

With that said, you have got to wonder if the contact will truly be just for satisfaction purposes - you may want to get a copy of the contact script to see if other motives are in play.

Just for clarification, the original post stated disclosure would be allowed under Reg P exceptions. Doesn't this mean, opt out(other than with feet down the street) would not be on option if sharing under the exceptions?

Getting ready to prepare for annual disclosure so Reg P issues are attractive to me these days.

You may be ok if they do not in any way try to solicit business - however, I would not personally want to be bothered by such a survey. You may have angry customers as a result.

Your email suggest that this info sharing falls under an exception in section ___.14 or ___.15. However, if this company performs marketing services for you, you would need to disclose the info sharing, but no opt out right would arise.

I am going to play the devil's advocate and say it is not OK.
First, I would check to see what your privacy notice says about information sharing. Does it state in any way that information provided to third parties for providing a service will be restricted to those purposes? If it does, I would argue that the arrangement described would not meet those purposes.
Even if your privacy notice does not make such a statement, I would argue that any information provided to a service provider should only be used for that purpose. My opinion is that the information in your scenario would be used for more than the intended purpose(s).
Any other thoughts?

I tend to agree with Ron on this one. The information provided to the vender is only provided for the service which is contracted.