There was much cheering when federal regulators finally released their Final Model Privacy Notice Form back in November.
That was quickly followed by a gnashing of teeth when it turns out the regulators did not understand the concept of a form or how to use Adobe Acrobat. They merely created a static document that you would have to spend hours trying to recreate.
They finally released version of the model privacy notice that is a fillable form using adobe acrobat.
To obtain a legal “safe harbor” and so satisfy the Gramm-Leach-Bliley Act’s disclosure requirements, institutions must follow the instructions in the model form regulation when using the Online Form Builder.