Sarah contacts Oakwood Financial Services to request a rate quote for a personal auto policy. She provides her driving history and ZIP code to the agent but ultimately decides not to purchase a policy. Under the Gramm-Leach-Bliley Act (GLBA), how is Sarah classified, and what privacy notice requirement applies to her?
- She is a consumer; a privacy notice is required only if the agency intends to share her nonpublic personal information with a nonaffiliated third party.Answer
- BShe is a customer; an initial privacy notice must be provided at the time the quote is generated regardless of information sharing.
- CShe is a consumer; the agency must provide both an initial and an annual privacy notice because her data was collected.
- DShe is a customer; the agency is entirely exempt from privacy rules because no insurance contract was legally formed.
Answer
She is a consumer; a privacy notice is required only if the agency intends to share her nonpublic personal information with a nonaffiliated third party.
The correct answer accurately classifies the individual as a consumer since she only requested a quote and did not buy a policy. Under the GLBA, a financial institution is only required to provide an initial privacy notice to a consumer if it plans to disclose that consumer's nonpublic personal information to a nonaffiliated third party.
Step-by-Step Solution
Key Concept
Under GLBA, a consumer (someone seeking a one-time service) only requires an initial privacy notice if their nonpublic personal information is shared with nonaffiliated third parties, whereas a customer (ongoing relationship) requires initial and annual notices.
Estimated Time:45s