Privacy Policy

Posted By: Carter'sMom

Privacy Policy - 11/13/17 06:34 PM

Do most banks have a formal privacy policy in addition to the privacy notice or are banks just using the wording in the notice as their policy?

Posted By: Monster

Re: Privacy Policy - 11/13/17 08:16 PM

I've seen it used both ways, but at my shop I prefer a separate policy from the notice, with the notice as an appendix.
Posted By: Adam Witmer

Re: Privacy Policy - 11/13/17 08:22 PM

I too have seen both ways, though bigger banks seem to have a separate policy while smaller banks just use their notice. Also, many ethics policies cover privacy which could eliminate the need for a separate privacy policy.
Posted By: Elwood P. Dowd

Re: Privacy Policy - 11/14/17 12:39 PM

Regulation P is a relatively unimportant regulation driven by the one time distribution of a disclosure. Any policy for that topic alone would be verbose once you passed the second paragraph; i.e. it is unnecessary.

The broader topic of "Privacy" would incorporate information security and all other ways that banks can hemorrhage customer information. It would be a double edged sword; i.e. you could make a grandiose statement that could be used against you in the wrong situation. Write it if you need it, but don't over promise.