Can I use third-party file sharing tools that collect personal information in Pennsylvania? What are the requirements?

According to the Pennsylvania Code, a licensee may not disclose nonpublic personal financial information about a consumer to a nonaffiliated third party unless certain conditions are met ^[2.3]. Additionally, a licensee may not disclose a policy number or similar form of access number or access code for a consumer’s policy or transaction account to any nonaffiliated third party for use in telemarketing, direct mail marketing or other marketing through electronic mail to the consumer ^[2.5].

Therefore, if the third-party file sharing tool collects personal financial information or access codes, it may not be used unless the licensee has provided the consumer with an initial notice, opt-out notice, and a reasonable opportunity to opt-out of the disclosure ^[2.3][2.5]. It is important to review the privacy policy of the third-party file sharing tool to ensure compliance with Pennsylvania law.

Source(s):

• [2.3] Limitation on disclosure of nonpublic personal financial information to nonaffiliated third parties.
• [2.5] Limits on sharing account number information for marketing purposes.

Jurisdiction

Pennsylvania

• Privacy