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WATDA has heard from several franchise dealers that manufacturers are requiring dealerships to post their privacy statement on the dealership web site.
The privacy statement to which the manufacturers are referring is the statement required under the Gramm Leach Bliley Act. This statement informs financial service customers of the dealership's policy in handling the customer's non-public personal information.
Because dealers tend not to disclose non-public personal information, WATDA drafted a stock form that a dealership can use to provide the required privacy disclosure to its financial services customers. WATDA has provided the same language below so that dealers can copy it to their web sites.
However, before using either the form or the web site text, dealers need to verify that they do indeed handle their customer's non-public personal information the way the disclosure says. If not, dealers should not use the form, or the language below and should get the appropriate disclosure text from their own legal counsel.
Providing the dealership's privacy statement on the dealership's web site does not change the requirements under the law that a customer receive a written privacy notice when obtaining credit. Any dealer offering financial services to its customers should be routinely providing the WATDA form #16 Notice to Customers Regarding Your Private Information, or a dealership form of similar function.
For additional information regarding Initial Privacy Notices and dealership privacy requirements please reference the following Bulletins: Bulletin 8, 2001; Bulletin 10, 2001; Bulletin 9, 2003; Bulletin 20, 2003; Bulletin 27, 2004; and Bulletin 11, 2005.
Copyright 2001, 2008: WATDA Form 16 is a copyrighted form. The text below is provided solely for reproduction on a WATDA member dealership's web site. This text may not be used for any other purpose.
Disclosure Text:
In connection with your transaction we may obtain nonpublic personal information about you and that information is handled as stated in this notice. This does not apply to information obtained in a non-financial transaction.
We collect personal nonpublic information about you from the following sources:
- Information we receive from you on an application for credit or other similar forms;
- Information about your transactions with us and others; and,
- Information we receive from a consumer-reporting agency.
Please be aware that it is our policy to disclose the above nonpublic personal information to only those companies that perform marketing services or other functions on our behalf or to other financial institutions with which we have joint marketing agreements.
We do not disclose any nonpublic personal information about you to anyone except as permitted by law.
Further, we restrict access to your nonpublic personal information to only those employees who need to know that information to provide products or services to you. Employees cannot use your information for any other purpose. For your safety, we maintain physical, electronic and procedural safeguards that comply with federal regulations to further guard your nonpublic personal information.
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