Both Illinois and federal privacy laws include exceptions for revealing a customer’s financial information with the customer’s consent. Under the federal law, Regulation P includes an exception to the prohibition on disclosing “nonpublic personal information” when done so “[w]ith the consent or at the direction of the consumer, provided that the consumer has not revoked the consent or direction.” 12 CFR 1016.15(a). Similarly, the Illinois Banking Act’s privacy provisions state that a bank may disclose a customer’s financial records to another person if “the customer has authorized disclosure to the person.” 205 ILCS 5/48.1(c)(1). We do recommend obtaining permission from the customers in writing and retaining that documentation.
One of our employees is speaking at an event for small business owners and wants to discuss some of the small business customers he serves, with their permission. Would any financial privacy laws prohibit us from revealing these customer relationships to the outside world?
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