Gramm-Leach-Bliley Act

Gramm-Leach-Bliley: Publicly Available Information

- Not included in term "nonpublic personal information" - Includes information in: + government real estate records (mortgage records, deeds) + widely distributed media (phonebook, unrestricted websites)

Gramm-Leach-Bliley: Safeguards Rule

- Implements security requirements of Gramm-Leach-Bliley - Financial institutions must implement and maintain policies to ensure safety/confidentiality of customer information. - Entity must: + conduct risk assessment + have safeguards to control risks identified + periodically update security program Companies must have a policy in place that protects personal info of their customers including security breaches. 1. Insure security and confidentiality of customer records and info 2. Protect against any anticipated threats or hazards to security or integrity of such records 3. Protect against unauthorized access to or use of such records or info which could result in substantial harm or inconvenience to any customer

Gramm-Leach-Bliley Act: Nonpublic Personal Information

- Protected by the Gramm-Leach-Bliey Act - Information collected by financial institution in connection with providing financial product or service to consumer - Includes: + name and address + Social Security number + account numbers - Does not include publicly available information

Gramm-Leach-Bliley Act

- Regulation P - Enforces disclosure of nonpublic personal financial information by CFPB - Includes + Safeguards Rule + Financial Privacy Rule

Gramm-Leach-Bliley Act: Opt Out Notice

- Required under Gramm-Leach-Bliley - Must be given with initial privacy notice - Advises customer of right/manner in which to opt out of having his nonpublic personal information shared

Gramm-Leach-Bliley Act: Financial Privacy Rule

-Governs collection/disclosure of customers' personal financial information - Requires provision of privacy notice to consumers prior to disclosing nonpublic personal information to non affiliated third party

Gramm-Leach-Bliley Act: Privacy Notice

- Required under Gramm-Leach-Bliley - Provides financial institution's privacy/information-sharing policies - Must be given to consumer prior to providing nonpublic personal information to nonaffiliated third party - Costomer must be provided annual notice