What Information is Shared?
Companies must also describe in their privacy notices the categories of nonpublic personal information that they share with their own affiliates. They are not generally required by law to provide an opt-out for data sharing with affiliates, but some companies do offer this option as well, at least for marketing contacts. Additionally, under the Fair Credit Reporting Act (“FCRA”), companies have for several years been obliged to provide notice and an opportunity to decline the disclosure to affiliates of information obtained from consumer reports. Some of the privacy notices mailed in 2001 include this FCRA notice as well, typically in a separate text box or insert. Next year, this will be the norm and all of the privacy-related notices will be in one mailing.
