Privacy of Consumer Financial Information
Regulation P (Privacy of Consumer Financial Information) protects against the misuse of private, non-public personal information. The Gramm-Leach-Bliley Act (GLBA), or Regulation P, requires financial institutions to explain their information-sharing practices and to safeguard sensitive data. Non-public personally identifiable consumer client information is highly protected, with very restricted access. Reg P applies only to consumers and does not apply to companies or individuals that obtain financial products and services for business, commercial, or agricultural purposes.
Non-public personally identifiable client information includes the client's name, address, or telephone number, in conjunction with the client's social security number, driver's license number, account number, credit/debit card number, personal identification number, or password that would permit access to the client's account.Personally identifiable client information also includes any combination of components of client information that would allow someone to log onto or access the client's account, such as user name and password or password and account number. Associates accept the responsibility for safeguarding client information by signing the Code of Conduct Acknowledgment form when hired.
Click here to access the CCB GLBA Privacy Policy.
Consumer clients can opt-in or opt-out of the following:
- External sharing of information privacy act (Regulation P) – information sharing with outside or non-affiliated companies
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Internal sharing of information (affiliate sharing) – information sharing within the Capital City Bank Group for marketing purposes
- Affiliates include:
- Trust Services
- Investment Services
- Capital City Home Loans (CCHL)
- Private Wealth
- Affiliates include:
- Do not call / Do not email preference – preferences for marketing telephone calls and/or emails from Capital City Bank
See Opt-Out Opt-In form.
Client Opt-in/out Status in Xperience
To view the status of a clients Privacy and Affiliate Opt out status, do the following:
- In Xperience > Customer & Account Inquiry.
- Enter the client's name, account number or Tax ID.
- Click the Customer tab.
- In the Contract Criteria section, review the Privacy Act Opted Out and Affiliate Opt Out information.
- Yes in either section indicates the client has opted out of information sharing.
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No indicates the client has not opted out.
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Consumer clients can opt-in or opt-out of the following:
- External sharing of information privacy act (Regulation P) – information sharing with outside or non-affiliated companies
-
Internal sharing of information (affiliate sharing) – information sharing within the Capital City Bank Group for marketing purposes
- Affiliates include:
- Capital City Trust
- Capital City Investments (CCI)
- Capital City Home Loans (CCHL)
- Capital City Wealth
- Affiliates include:
- Do not call / Do not email preference – preferences for marketing telephone calls and/or emails from Capital City Bank
- If a client wants to opt-in or opt-out, do the following:
- Open the Opt-Out Opt-In form.
- Complete the form with the preferences of the client.
- If the client is physically present, obtain client signature.
- Scan the completed form and send to _Deposit Svc - Input and also scan with your daily work.
FAQ's
Below are the frequently asked questions in regards to Reg P:
How do you handle identification information for clients/consumers cashing checks?
Enter the identification information while processing the transaction. Do not write the ID information on the check.
Does CCB require an account number on the back of negotiated items?
No. To avoid a potential Reg. P violation, associates must not write an account number on any check being cashed or deposited.
If a client uses a deposit stamp that includes his/her name and account number, do you mark out the first and last two digits to disguise the account number?
No. If the client stamps the back of the check, we have evidence that the client authorized and performed this act. The bank did not place the information on the check and is not responsible for removing it. This applies to both business and consumer accounts.
If a client writes his/her account number on the back of the check do you mark through the first and last two digits?
For consumer clients -- Yes. We should do so if the client is a consumer (because there is no clear evidence of who placed the account number on the check, and the client could later allege that we had done it).
For business or commercial accounts -- No. It is not necessary for a business or commercial account since Reg P does not apply.
Can you record identification on the back of redeemed savings bonds?
Yes. As a condition of acting as a redemption agent, the government requires us to obtain and record ID information on the back of the bond. Reg P does not change any existing government requirement to obtain or provide information to the government in specific cases.
Can you discuss an account with a member of the client’s family who is not a signer on the account, if the client has given verbal permission for you to talk to them? Does the client’s permission need to be in writing?
If you have client authorization in writing to release information to that family member, it is permissible to discuss the account with them. Without written authorization from the client, do not say anything about the account to other family members that are not signers on the account unless the client is present and gives you authorization.
How do you handle bank-to-bank verification of funds or merchant verification of funds or verification of funds for non-banks and non-merchants (for example: individuals)?
Do the following:- Ask the caller for our client’s account number, the amount of the check, and the check number.
- Examine the account history to verify that the number of the check would fit in the sequence of check numbers recently paid on the account. Do not verify funds without checking to see if the number on the check is a number close to the range of recently paid check numbers.
- Check the available balance to see if the check would pay upon presentment.
- Respond to the inquiry, but communicate only one of the following:
- Yes, the check would pay at this moment
- No, the check would not pay at this moment
- The account is closed
- Do not give any other information (for example: address, telephone number, date account closed) to the caller without written authorization from the client.
Can you make a copy of a check for a client before he or she cashes or deposits the item?
Yes. You are not giving the client any information that he/she does not already have and is not already entitled to copy. You are merely providing a common service available at any copy center.