Thinking About What Privacy Means

Alan Greenspan, at the 1997 Conference on Privacy and the Information Age, observed that "the dictionary defines privacy as the state of being free from unsanctioned intrusion."

In her June 22, 1999 speech to OCC Chief Counsel, Julie Williams quoted Justice Louis Brandeis' description of privacy, "the right to be left alone - the most comprehensive of rights, and the right most valued by a free people."

Williams also stated that "Privacy as an individual right implies that to some degree personal and private information about an individual is the property of that individual. That also implies that when a customer gives that property to another for one express purpose, he or she is not implicitly giving it for whatever other purposes the recipient may want to use it."

Governor Edward M. Gramlich stated that there is a "collision between economic interests in the value of customer information and individual privacy interests." This is, he believes, an "inevitable consequence of the growth in information technology." Before the Subcommittee on Financial Institutions and Consumer Credit, July 21, 1999.

Gramlich also stated that "it is clear that many consumers believe that an implicit contract exists between the financial institution and the customer that requires the financial institution to keep certain transactional information confidential." Before the Subcommittee on Financial Institutions and Consumer Credit, July 21, 1999. "[I]f banks fail to honor customer expectations that personal information will be kept private and confidential, they will impair the most priceless asset of their banking franchise - their customer's trust." Testimony of John D. Hawke, Jr. before the Subcommittee on Financial Institutions and Consumer Credit, July 21, 1999.

"Privacy policies are meaningful only if they reflect an organizational commitment, are adhered to, are stated in terms customers can readily understand, and meet legitimate customer expectations about the handling of their personal information." Remarks by Julie Williams, Chief Counsel, OCC, before the Financial Institutions Insurance Association, June 22, 1999. Copyright © 1999 Compliance Action. Originally appeared in Compliance Action, Vol. 4, No. 13 & 14, 11/99