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WASHINGTON-While banking representatives said they felt they did all they could to present clear privacy notices to consumers under the Gramm-Leach-Bliley Act (GLBA), improvements were a key focus of last week’s workshop held by the GLBA regulators, including NCUA. The well-attended meeting was moved from the Federal Trade Commission Headquarters to the Ronald Reagan Building a few blocks away when the group realized the popularity of the event. Many of the bankers who spoke at the meeting touted their privacy policy’s question and answer format or consumer focus groups used in creating a privacy policy. They blamed the regulation for difficulty in creating a clear, concise disclosure. No credit union representatives spoke at the workshop. The bankers’ privacy efforts were not good enough said some educators and consumer advocacy groups. Dr. Deborah Bosley, director of the university writing programs at the University of North Carolina at Charlotte recommended that privacy notice drafters should focus on visual appeal and plain language. In doing so, the notices should contain white space, readable typefaces (minimum of 10 point type), headings of substance, bulleted or numbered items to break up and emphasize, and shorter sentences and paragraphs. Additionally, disclosures should use a `you-attitude’ (for example, emphasizing a consumer’s right to opt-out of information sharing), use common words when possible and define when necessary, write in the active voice, and positive wording (explain matters in terms of what is permitted, rather than what cannot be done). A recent survey of 2,053 American adults over 18 performed by Harris Interactive found that these suggestions could be key to consumers’ favorable opinion of GLBA privacy notices, Harris Interactive Senior Vice President David Krane said. Some of the survey’s key findings include: * 77% of respondents favored a short, concise privacy policy; * 70% of respondents agreed that companies “should use the same summary or checklist for their privacy policies”; * Only 3% of respondents reviewed online privacy notices carefully most of the time while nearly 64% did not read notices at all or have only glanced at them; * Only 12% reported reviewing financial notices carefully; and * The top reasons cited for not reading privacy policies more carefully were a lack of time/interest and a high level of difficulty understanding the notices. Citizen Action of New York Health Care Project Director Joy Gould explained that USAction, a national consumer organization, provided 15 banks’ privacy notices report cards, none of which were worthy of the honor roll. According to the study, nine of the 15 banks received a D or F on providing legally required information in an understandable manner. The highest overall grade among the banks was a C. The group noted that one bank does not make its notice available until after receiving personal information from the consumer. MBNA, the largest credit card issuing bank in the U.S., received the lowest grade; according to USAction MBNA’s privacy notice was “very hard to read,” consumer opt out rights were “buried” in the middle of a paragraph, and the banks provides little information on how it uses the consumer’s information. One positive point about he GLBA requirements came out of a Star Systems Survey, which found that when consumers are unfamiliar with their financial institutions’ privacy policies they are more likely to be concerned about their financial privacy. [email protected]

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