As in the current version of the “Sample Clauses,” the disclosure table includes a description of the possible types of information sharing in which an institution engages, the uses of the consumers’ personal information, and the opt-out choices that must be disclosed. Consumers are to be provided with “Supplemental Information,” including answers to common questions and relevant definitions. The last page of the disclosure is an opt-out form, which, as in the past, is provided only of the institution (i) shares or uses in formation in a manner that triggers the opt-out requirement or (ii) chooses to provide the opt-out beyond what is required by law. An institution will need to tailor the opt-out page to accurately reflect its actual practices.
The proposal provides guidelines regarding the appearance of the model form including font sizes, font style, spacing, paper and ink color and overall readability.
- Michael Tomkies and Kathleen Manley