Exam CIPP-US topic 1 question 199 discussion

The IAPP textbook does not cover this case. I had to research the web to find the answer. Here it is: https://www.federalregister.gov/documents/2018/08/17/2018-17572/amendment-to-the-annual-privacy-notice-requirement-under-the-gramm-leach-bliley-act-regulation-p The relevant part is below: "On December 4, 2015, Congress amended the GLBA as part of the Fixing America's Surface Transportation Act (FAST Act).... This subsection provides an exception under which financial institutions that meet certain conditions are not required to provide annual privacy notices to customers. In addition, section 503(f)(2) requires that the financial institution must not have changed its policies and practices with regard to disclosing nonpublic personal information from those that the institution disclosed in the most recent privacy notice it sent.

In December 2015, Congress amended the GLBA as part of the Fixing America’s Surface Transportation Act (FAST Act). This amendment provides financial institutions that meet certain conditions an exemption to the requirement under the GLBA to deliver an annual privacy notice. A financial institution can use the annual notice exception if it limits its sharing of customer information so that the customer does not have the right to opt out and has not changed its privacy notice from the one previously delivered to its customer.