Answer:
Answer by Andy Zavoina:
In short, no.
The ATM user has no continuing relationship with you.
Answer:
Answer by Jim Bedsole:
I believe you would have to provide the short-form notice, along with an opt-out form prior to sharing (except as allowed under __.14 and __.15) any identifiable nonpublic personal financial information about the users of your ATM. However, if you are not going to share any identifiable information about the users, you do not need to post the short-form privacy notice.
Notice required for consumers - __.4(a)(2)
Short-form notice with opt-out acceptable - __.6(d)
Opt-out OK in electronic form - __.7(b)
For ATM consumers, notice and opt-out OK on ATM screen - __.9(b)(iv)
No notice required for consumers that are not customers if you are not sharing - __.4(b)
First published on BankersOnline.com 06/16/03
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