Can the privacy notices that are required by the regulation be delivered in newsletters or group administrator manuals?
It depends. There is no requirement that the notices be delivered alone or independent from other information. However, the notice must be clear and conspicuous and be designed to call the consumer or customer’s attention to the importance of the information in the notice. Delivery of privacy notices in a newsletter or administrator manual might be considered “reasonable” if the notice is clearly distinguishable from other information and it is placed in a prominent position in the newsletter or manual. However, it is likely that delivery would be found unreasonable, if the notice blends in with other information and is buried deep within the manual or printed in small type on the back of the newsletter.
Related Questions
- To a group, are we covered if we provide Notice of Privacy Practices to the group administrator, or does notice need to be provided to each and every eligible employee?
- Can the privacy notices that are required by the regulation be delivered in newsletters or group administrator manuals?
- A user wishes to have their group membership changed/become an administrator/leave a group?
