Privacy Opt Out

Posted By: Melissa

Privacy Opt Out - 10/09/19 09:14 PM

We were looking at how other banks would handle the below scenario:

Our privacy notice states that when a joint accountholder opts out of information sharing, the opt out will apply to everyone on the account. That’s consistent with the regulatory requirement.

We have a scenario we would like to run by you: Stacey opts out. She has a joint account with RJ and a joint account with Kelsey, which means that RJ and Kelsey are opted out as well. Simple enough. But now that RJ is opted out, what about his joint account with Samuel? And what about Kelsey’s joint account with Landon? Should Samuel and Landon be opted out as well?

I appreciate any input. Thanks!
Posted By: TomS

Re: Privacy Opt Out - 10/09/19 09:49 PM

I would say no. RJ and Kelsey are opted out only because Stacey opted out. For the accounts that RJ and Kelsey hold jointly with others, one of the accountholders on those accounts would need to affirmatively opt out. Since Stacey has nothing to do with those two accounts, her decision to opt out should have no effect on them.
Posted By: Melissa

Re: Privacy Opt Out - 10/11/19 01:10 PM

Thank you for your input Tom. This was our thought as well, but have heard conflicting information so wanted to open it up to others as well.