Proskauer on Privacy

Tag Archives: Gramm-Leach-Bliley

Feud of the Forms — The Battle of The GLBA Notices

The report by Drs. Alan Levy and Manoj Hastak, Consumer Comprehension of Financial Privacy Notices, uses the results of a mall-intercept study to compare the performance of a prototype financial privacy notice developed by the Kleimann Communication Group ("KCG") during the first phase of the INP against three alternative notices. The Levy-Hastak report, among other things, confirms what proponents of the INP suspected - some GLBA privacy notices are largely ineffective in conveying information to consumers that allows them to make rational decisions about the sharing of their personal financial information. … Continue Reading

FTC Sets Sights on Goal: Student Lender Taken to School for Data Security Breakdowns

On March 4 the FTC announced that a consent agreement has been reached in its 17th case challenging data security practices by a company handling sensitive consumer information. Goal Financial, LLC, a San Diego-based student loan company, has agreed to implement a comprehensive information security program, avoid future misrepresentations about its data security practices, and receive independent, third-party audits of its data security program every two years for the next 10 years. The consent order does not provide for a civil fine. … Continue Reading
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