One of my affiliates sells insurance. May the plumbing company, who received my customers’ information outside an exception, disclose that information to my affiliated insurer?
A. Yes. The Privacy Rule explicitly provides that the plumbing company may disclose the information to your affiliate. §___.11(d)(1). G.6. Q. I disclosed information to the plumbing company outside an exception. The plumbing company is affiliated with an air conditioning company. The air conditioning company is not affiliated with me. May the plumbing company disclose my consumers’ nonpublic personal information to that air conditioning company? A. Yes. The Privacy Rule permits a party that receives nonpublic personal information outside of an exception to disclose that information to its affiliates. In this case, therefore, the plumbing company may disclose the information to its affiliated air conditioning company. However, the affiliated air conditioning company may, in turn, disclose the information only to the extent that the plumbing company may, consistent with your privacy notice. §___.11(d)(2). G.7. Q. I disclosed information to the plumbing company outside an exception. May t
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