Can anyone share whether or not you have amended your bank's privacy notice specifically the one you post on your website to include captions such as "Use of this Website", "Email", and "Other Sites". We currently have a privacy notice that we mail annually to all customers, provide in new account openings etc. that does not have this verbiage. We have never been criticized for having two different versions but now we feel that with a new more interactive website that we need to make very sure before it goes live to customers.

Our bank has two different privacy notices, but we do not open accounts through the Internet. Our website policy indicates we will not share nonpublic personal financial information obtained from their use of the website until they have received our privacy disclosure and opt-out notice.

If you do open accounts through your Internet website, I think you want your bank's privacy disclosure to be on the website. (Watch out for external links that may result in unintentional sharing of information that is contrary to your policy.)

At one time I thought two separate notices was a good thing as the customer in the lobby didn't care if you had cookies mentioned, as one example. I have reconsidered this and now believe one notice is best.

The Privacy Policy need not be on your web site unless you open accounts there or deliver it via an E-Sign agreement. But I do think it is a good reference and would put it there for simplicity sake. And because I believe it is a stretch to think your customer will read it once, it is a real leap to think they'll read a second version on the web. So I'd go with one complete disclosure and let the customer base as a whole know your on line and off line policy in one single version. This makes updates easier too.

I'm with you, Andy. This is a perfect application of k.i.s.s. Whenever a bank can eliminate variety it eliminates the chance of violations. Besides--the regulation (Sec. 216.6) requires that ALL information has to be included in order for a notice to count. Web site privacy notices I've seen only cover the part of the banks' privacy policy that applies to the web site, not the whole bank.