Posted on 03/10/2016 at 12:00 AM by John Lande
Almost every business now has an online presence. Many businesses, including financial institutions, have expanded their online presence to include interactive features that collect customer information. This information can be valuable to businesses and provide added convenience to consumers. However, organizations that find themselves in possession of private consumer information should be careful to protect that information from unauthorized access.
Under the Gramm-Leach-Bliley Act (“GLBA”), financial institutions are required to provide consumers with privacy policies that explain to consumers how their personal information will be protected and used. The Consumer Financial Protection Bureau (“CFPB”) has enforcement authority over privacy policies for financial institutions while the Federal Trade Commission (“FTC”) enforces privacy obligations for non-financial organizations. Both the CFPB and FTC have the authority to enforce the privacy requirements if either agency considers an organization to be engaged in unfair, deceptive, or abusive acts or practices (“UDAAP”).
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