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#888109 - 01/15/08 08:59 PM Can we do this
Sotally Tober Offline
Junior Member
Sotally Tober
Joined: Jan 2004
Posts: 48
SW Missouri
I just found out from a teller at our new branch that the new branch manager has the tellers from another branch making copies of a large commercial account they have ( convenience store/gas station) and is having her tellers at the new branch typing letters to all of this commercial account customers letting them know about this new branch. Now mind you these are not our customers they are customers of our commercial customer, they are getting names and addresses from the checks that he is depositing. Apparently she got it approved by the president but did not run it past me, the compliance officer, maybe I am wrong but this seems to violate privacy rules.

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#888314 - 01/16/08 01:26 AM Re: Can we do this Sotally Tober
rlcarey Online
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Joined: Jul 2001
Posts: 80,827
Galveston, TX
This is typically referred as data mining. Nothing illegal, just some reputation risk if the commercial customer finds out that you are using their deposits for marketing purposes.
The opinions expressed here should not be construed to be those of my employer:

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#888499 - 01/16/08 04:14 PM Re: Can we do this rlcarey
texasbanker123 Offline
Junior Member
Joined: Jan 2008
Posts: 27
this seems very morally wrong. all the information a banker should use should be on a 'need to know' basis. you do not need to know random people's addresses to send them advertisements.

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#888516 - 01/16/08 04:21 PM Re: Can we do this texasbanker123
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Right or wrong, businesses do it all the time.
I don't repeat gossip, so listen closely...

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#891964 - 01/23/08 03:46 PM Re: Can we do this #Just Jay
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
It is public information anyway, why not use it? I can get their addresses and names from the county appraisal district's website...

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#896208 - 01/30/08 04:31 PM Re: Can we do this Sotally Tober
MoneyMaker Offline

100 Club
Joined: Dec 2000
Posts: 215
Atlanta, GA USA
I feel you are walking a very thin line. If your letters are stating, suggesting that your commercial customer has an account with your bank and you haven't received your customer's permission to say this, I think you are dangerously close to violating the privacy act. As I understand the act, you cannot state customer relationship unless it is available through public resources.
Short cuts to bank revenue growth and higher employee happiness.

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#897034 - 01/31/08 02:07 PM Re: Can we do this MoneyMaker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,929
Cape Cod
I agree with Rick that it would be a big mistake to divulge to these third parties that the C-Store/Gas Station has an account with you. However, I don't see in the original question that the bank proposes to mention its customer at all. They appear to be mining the names and addresses they find on checks deposited to the C-Store's account to create a mailing list to use in announcing their new office.

I don't believe they plan to reveal the source of their mailing list information.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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