Sharing Information for Joint marketing

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Question:

Our bank shares nonpublic personal information with an unaffiliated third party with whom we have a joint marketing arrangement for marketing credit card accounts. Under the agreement we are required to provide them in an electronic format the names, addresses, telephone numbers and social security numbers of our existing customers for the purpose of allowing them to solicit our customer for credit card accounts. Are we allowed to disclose telephone numbers and particularly social security numbers without providing our customers the opportunity to opt out? Our initial and annual disclosures do contain the required verbiage that we may disclose all of the information we collect to companies that perform marketing services on our behalf or with whom we have joint marketing agreements?

Answer:

If you are providing "non-public" customer information, you need to make darn sure you are covered with your customers, recently, with the opt-in-out permission. If your customers have unlisted telephone numbers you might bet a little burned around the edges of "privacy". And I am not clear why your third party needs social security numbers before they get the new account??? Be careful!!

First published on BankersOnline.com 12/15/03