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Privacy and Outsourcing Loan Reviews

Answered by: 
Jim Bedsole
Bob McComas

Question: 
What are the privacy issues related to having a contract person providing loan analysis as opposed to a full-time employee? This person would be required to see financial statements, credit reports, and other personal information about existing customers.
Answer: 

As a service provider, this person would fall under GLB privacy regulation exceptions in Section ___.13(a). You do have to have a contractual arrangement with that person that prohibits them from disclosing or using the information other than for the purposes for which you gave them the information. Also, under the Information Security guidelines, your contract with this person should also stipulate that they will adhere to your standards of information security with regard to the customer information in their possession.

First published on BankersOnline.com 10/4/04

First published on 10/04/2004

Filed under: 
Compliance
Security
Filed under compliance as: 
Customer Information
Information Security Guidelines
Outsourcing
Privacy
Security
Service Provider
Statements
Filed under security as: 
Customer Information
Information Security Guidelines
Privacy
Security
Service Provider
Statements

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