Feds Release Usable Model Consumer Privacy Notice

There was much cheering when federal regulators finally released their Final Model Privacy Notice Form back in November.

That was quickly followed by a gnashing of teeth when it turns out the regulators did not understand the concept of a form or how to use Adobe Acrobat. They merely created a static document that you would have to spend hours trying to recreate.

They finally released version of the model privacy notice that is a fillable form using adobe acrobat.

• Instructions for using the Privacy Notice Online Form Builder
• If you provide an opt out and you want to include affiliate marketing, use Form 1.
• If you provide an opt out and you do not want to include affiliate marketing, use Form 2.
• If you do not provide an opt out and you want to include affiliate marketing, use Form 3.
• If you do not provide an opt out and you do not want to include affiliate marketing, use Form 4.

To obtain a legal “safe harbor” and so satisfy the Gramm-Leach-Bliley Act’s disclosure requirements, institutions must follow the instructions in the model form regulation when using the Online Form Builder.

Sources:

• Instructions for using the Privacy Notice Online Form Builder
• SEC Press Release – Federal Regulators Release Model Consumer Privacy Notice Online Form Builder
• Federal Regulators Issue Final Model Privacy Notice Form – prior post