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Can I use customer data for marketing purposes without violating privacy laws in Michigan? What are the requirements?
Using Customer Data for Marketing Purposes in Michigan
In Michigan, using customer data for marketing purposes is allowed if the licensee adopts policies and procedures for administrative, technical, and physical safeguards for the protection of customer records and information [1.6]. The policies and procedures must be based on the guidelines adopted by the Commissioner and must be reasonably designed to ensure the security and confidentiality of customer records and information, protect against any anticipated threats or hazards to the security or integrity of customer records and information, and protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer [1.6].
A record or information described in section 2 may be disclosed for the purpose of marketing goods and services to customers if the person that is disclosing the information informs the customer by written notice that the customer may remove his or her name at any time and specifies the manner or manners by which the customer may remove his or her name. The written notice must include a nonelectronic method that the customer may use to opt out of disclosure. The customer may provide notice to the person that is disclosing information that the customer does not want his or her name disclosed [2.2].
Therefore, to use customer data for marketing purposes in Michigan, you must adopt policies and procedures for administrative, technical, and physical safeguards for the protection of customer records and information. Additionally, you must inform the customer by written notice that he or she may remove his or her name at any time and specify the manner or manners by which the customer may remove his or her name [1.6][2.2].
Source(s):
- [1.6] Protection of customer records and information; adoption of guidelines for administrative, technical, and physical safeguards.
- [2.2] Exceptions.
Jurisdiction
Michigan