BOSTON-Often when credit union officials and others in the financial services industry hear the word privacy, the first thing that comes to mind is regulations and privacy notices. According to Fidelity Investment Chief Privacy Officer Leigh Williams, that should not be the case, even though those matters are important. Member concerns should be a first priority, he told attendees of NAFCU's 36th Annual Conference. In the two years that he has headed the privacy division of the firm, Fidelity has voluntarily instituted an opt-in privacy policy. Now that the privacy notices required under Gramm-Leach-Bliley have been implemented, Williams said it is time to begin perfecting those notices and keeping them fresh. "I think we've at least begun to move from a compliance driven [mentality] to more of a customer driven one," he remarked. Williams recommended credit unions conduct surveys and hold focus groups and really listen to what members have to say. "Don't take it and fudge around with it because the regulators will let you. Take it and respect it," he suggested. Williams said that he has brought a marketer onto his staff at Fidelity to help market privacy to their customers. One innovation that Fidelity has made is moving from a system of giving its lists to American Express, having them match up the two companies' customer lists, and mailing out offers for American Express services to the matches, to a system of providing the two lists to an outside party to match up, getting back the matches, and Fidelity mailing out marketing materials for American Express services to those matches. Under the new system, neither company sees the others customer information and, Williams said, Fidelity customers may be more likely to use an American Express service if it comes from a company they already trust. On the legislative scene, Williams sees opt-in privacy legislation being passed within the next 10 years and believes it would be a positive step. [email protected]