General Information Guide for GLB Compliance

The following document is a sample intended to give a general overview of the elements required in communique under the provisions of the Gramm-Leach-Bliley (GLB) Act of 1999 Note please that this site is for reference only, and is provided as a mechanism by which the user might familiarize herself with the general requirements of GLB and -- having done so -- seek further information with which to ensure her full compliance with that act. This page is designed as a sample of the sort of organizational communique which might accurately be supposed to effectively convey some of the requirements of the act. In no way is this to be considered exhaustive, nor are its authors to be considered as representatives of any governing body concerning the GLB. In particular, the authors of this site affirm no allegiance with whatever party decided on the background image of the GLB site. To quote Will Smith in "Men in Black" : 'Cause, damn!

Context

• The GLB Act requires every consumer to individually receive an updated Privacy Policy annually. This statement must be sent via paper mail unless the consumer authorizes reception via email.
• The ACME Group is responsible for sending a Privacy Policy on behalf of all its Agency-clients.

 

Objective

• ACME Group sends each enrolled debtor a paper or electronic-based copy of the Privacy Policy by February 7, 2003 (Friday).

 

Implementation Guidelines

·       Exhibit A depicts the process and timeline for sending paper-mail vs. email.

·       We will need to develop a database that tracks each debtor the following:

• Medium chosen
• Date sent
• If not email, reason: no email on file, bounce, no reply.
• If paper mail, any statements that are returned to sender.

·       Need separate address for from and reply to:

• From address: Agency_X-PrivacyPolicy@xxx.org
• Reply To address:  Agency_X-PrivacyPolicy(Reply)@xxx.org

 

Content

·       Permission Email:

 

Subject: Account Update from Agency X

 

Dear Mr. Smith,

 

<Our Agency> recognizes that joining a debt management plan requires you to share sensitive, personal information with us. For your benefit, we will soon be sending you a Privacy Policy to help you understand how we protect your financial privacy.

 

As a convenience to you, we would like to send the Privacy Policy to your email account. By clicking on the link below, you are authorizing us permission to send the Privacy Policy to your email account: 

 

Click here: (hypertext link)

Yes – I wish to receive the Privacy Policy through my email account.

No – I prefer to have the Privacy Policy statement mailed to my home address.

 

Thank you for you time and attention. Have a great day! 

 

·       Paper-mail/email that delivers Privacy Policy.

Subject: Important Notice from Agency X- Privacy Policy

 

Dear Mr. Smith,

 

This transmission is our updated Privacy Policy of <Agency X>. It aims to help you understand how we protect your financial privacy. Please read the Privacy Policy. If you need to reach us, the Policy includes contact information at the end of the statement.

 

Thank you for you time and attention. Have a great day! 

 

 

 

Exhibit A