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What do Banks, Insurance companies, Brokerages, plastic surgeons, and travel agencies have in common?

Under the privacy rules imposed as part of the Financial Services Modernization Act (a/k/a the Gramm-Leach-Bliley Act, or "GLB") financial institutions are restricted in their ability to use and disclose personal financial information of consumers. Financial institutions must -- every year -- disclose to consumers its privacy policy and provide 'opt-out' procedures to each consumer with whom it has a continuing relationship.

But you're not a bank, so you're immune from GLB compliance, right? Guess again. The privacy provisions of GLB can apply to any company engaged in financial services -- whether or not you are affiliated with a bank. Finance companies, insurance agencies, medical offices, securities dealers, even travel agencies and law firms can find themselves covered under GLB's broad definitions.

As GLB compliance efforts evolve, they are shaped by various rulings and enforcement actions undertaken by the US Department of the Treasury, the Federal Reserve, the OCC, the FDIC, the OTS, the SEC, the NCUA, and the FTC. Some issues remain, including the meaning of things like what is a "continuing relationship," what constitutes sufficent notice, what form and manner must the opt-out take, and more. And some of those issues have already been answered in ways that raise more questions.

PrivacyClue can help you assess whether, and to what extent, GLB applies to you. Our consultants can help you design a privacy policy and opt-out process that complies with GLB. If needed, our strategic partnerships with several software and hardware providers and technology implementation firms can help you implement scalable, reasonably priced opt-out processing, tracking, and auditing systems -- and get them in place fast.

PrivacyClue offers short- and long-term engagements at hourly or fixed-rates for every budget. We can help you stay GLB compliant at a fraction of the cost of responding to a Federal Trade Commission inquiry.

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