We believe you may use the information you receive from the drawing participants for marketing purposes, provided that you clearly and conspicuously disclose that you are collecting the participants’ contact information for marketing purposes. Because you will not be disclosing the contact information to third parties, the drawing should not trigger federal or Illinois privacy requirements.

Illinois law requires certain disclosures for advertising and offering prize drawings. The Consumer Fraud and Deceptive Business Practices Act requires you to clearly and conspicuously disclose all material terms and conditions relating to a prize offer at the outset of the offer. 815 ILCS 505/2P. In addition, the Prizes and Gifts Act requires nine disclosures to be made with any written promotional prize offer. 815 ILCS 525/25. We believe these laws require you to disclose to participants that their contact information is being collected for marketing purposes.

However, we do not believe that this information collection would raise significant privacy concerns. As you have described the drawing, it will not involve the disclosure of any information about the participants. Instead, your institution will be collecting the information and using it only for marketing purposes — the information will not be disclosed to any third parties. In any event, both Illinois and federal privacy laws exempt any consensual disclosures, and with proper disclosures, you may be able to assume that the participants have consented to your use of their contact information after the drawing. 12 CFR 1016.15(a)205 ILCS 5/48.1(c)(1).