Answer:
If the change to your privacy policy will result in, directly or through any affiliate, disclosure of any nonpublic personal information about a consumer to a nonaffiliated third party other than as described in the initial notice that you provided to that consumer under Section ___.4 of the GLBA privacy regulations, you must provide the consumer an updated notice in advance and provide the consumer a reasonable opportunity to opt-out (if an opt-out is available). See Section 216.8 of Regulation P.
First published on BankersOnline.com 3/28/11