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Violation for Distributing Privacy Notices

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Question: 
We currently have a vendor for our credit card product distributing privacy notices that are dated for the year 2012. While we are using the model form with accurate information, and our clients are receiving a privacy notice, I am concerned about the date of 2012 and if we are in violation or could face potential fines?
Answer: 

The instructions for the model form state that the date in the upper right hand corner is the date last revised. If you have not made any revisions to your privacy notice since 2012, then there is no need to change the date each year. For the sake of consistency, if your privacy notice on your website or annual mailing has a different date, it is appropriate that you provide them with the same form that is provided to other customers.

First published on 06/14/2015

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