Annual Privacy Mailing

Our annual privacy mailing is every July, however in January 2011 we implemented the new privacy model form and did a mass mailing to all consumer customers (also in January 2011). Since our customers have received the new model notice in January, do I need to still do my July annual mailing, or did the clock reset in January, thereby making my next annual privacy mailing set for January 2012? I hate to incur the cost of doing another mass mailing when all we would be doing is providing the same information to the recipients.

Any help would be greatly appreciated.

IMO- Clock reset... Your new annual mailing schedule is January 2012.

Here is the reference- To me "at least once in any period of 12 consecutive months..." is the key for your situation. You did that.

§ 216.5 Annual privacy notice to customers required.
(a)(1) General rule. You must provide a clear and conspicuous notice to customers that accurately reflects your privacy policies and practices not less than annually during the continuation of the customer relationship. Annually means at least once in any period of 12 consecutive months during which that relationship exists. You may define the 12-consecutive-month period, but you must apply it to the customer on a consistent basis.