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Can I use third-party marketing automation tools that collect personal information in Illinois? What are the requirements?

Marketing Automation Tools and Personal Information Collection in Illinois

Illinois has strict regulations regarding the collection and sharing of nonpublic personal financial information for marketing purposes. The Illinois Administrative Code (ILAC) provides guidelines for the use of third-party marketing automation tools that collect personal information.

Limits on Sharing Account Number Information for Marketing Purposes [1.3]

Under ILAC 4002.120, financial institutions are prohibited from sharing account number information for marketing purposes unless the customer has been given notice and a reasonable opportunity to opt-out.

Limits on Disclosure of Nonpublic Personal Financial Information to Nonaffiliated Third Parties [1.7]

ILAC 4002.100 limits the disclosure of nonpublic personal financial information to nonaffiliated third parties unless the customer has been given notice and a reasonable opportunity to opt-out.

Exceptions to Notice and Opt Out Requirements for Disclosure of Nonpublic Personal Financial Information for Processing and Servicing Transactions [1.8]

ILAC 4002.140 provides exceptions to the notice and opt-out requirements for disclosure of nonpublic personal financial information for processing and servicing transactions.

Other Exceptions to Notice and Opt Out Requirements for Disclosure of Nonpublic Personal Financial Information [1.9]

ILAC 4002.150 provides other exceptions to the notice and opt-out requirements for disclosure of nonpublic personal financial information.

Based on the above regulations, if a third-party marketing automation tool collects nonpublic personal financial information for marketing purposes, the financial institution must provide notice and a reasonable opportunity to opt-out to the customer. If the tool is used for processing and servicing transactions, exceptions to the notice and opt-out requirements may apply.

It is important to note that this is not an exhaustive list of regulations and requirements. Financial institutions should consult with legal counsel to ensure compliance with all applicable laws and regulations.

Therefore, it is possible to use third-party marketing automation tools that collect personal information in Illinois, but financial institutions must comply with the notice and opt-out requirements outlined in the ILAC.

Source(s):
Jurisdiction

Illinois