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| Take the Cloze Test: By July 1, 2001, and once a year thereafter, banks and other financial services companies are mailing privacy notices to their customers. These notices are a requirement of a new federal law, the Financial Services Modernization Act. (See Fact Sheets 24, 24(a) and 24(c) on the PRC web site at www.privacyrights.org for more information.) The privacy notices explain how you can "opt out" of having your customer data sold to other companies. Pay attention to the mail you receive from your bank, insurance company, credit card company, and brokerage firm. Look for words such as "Privacy Notice," "Privacy Policy," and "Opt-Out Notice." You might receive such notices via e-mail if that is the way you normally do business with these companies. But are these notices readable to the average person? Test your understanding of a typical privacy notice by taking the Cloze test. Below are portions of two banks' privacy notices. (See Cloze Test #1 and #2) Every fifth word is left out. Print these out and try to fill in the blanks. From the words that are there, see if you can fill in the missing word. If you get stuck, go on and come back later if you wish. Perhaps more than one word will make sense, but choose the one word that seems best to you. Don't worry if you can't get them all. Hardly anyone does. The answers and instructions on how to determine your score are provided below. We invite you to print these out, make copies, and give them to your friends, colleagues, and relatives. Feel free to share the results with us. For information about our confidentiality policy and how to reach us, see below. About the Cloze Test. The Cloze Test provides a good way to measure how well "average" consumers actually understand key sections of written material, in this case the notice. It is based on the psychological principle of "closure." The Cloze Test deletes every fifth word, and the reader is asked to fill in the blanks. If the notice is well written, the reader should be able to fill in the blank based on the rest of the sentence, thus obtaining closure. If the notice is not well written, the reader will not be able to fill in the blank because the reader can't understand the sentence. Cloze Test #1. From a Bank's Privacy Policy Confidentiality and Security: We restrict access to personal information about you to those employees who need to have that information to provide products or services to you. We maintain up-to-date physical (1)____________ (like secure areas in (2)____________), electronic safeguards (like encryption) (3)____________ procedural safeguards (like customer (4)____________ procedures to prevent identity (5)____________). These safeguards exceed federal (6)____________ to protect personal information (7)____________ you. We train our (8)____________ on their roles in (9)____________ this personal information and (10)____________ regular internal audits to (11)____________ our commitment. Sometimes we (12)____________ other companies to provide (13)____________ for us such as (14)____________ card embossing services and (15)____________ select these companies carefully. (16)____________ must keep the information (17)____________ share with them safe (18)____________ secure and we do (19)____________ allow them to use (20)____________ share the information for (21)____________ purpose other than the (22)____________ they are hired to (23)____________. Information we may share in our family of companies. In order to offer (24)____________ additional products and services (25)____________ may share the information (26)____________ on page 1 under "Information (27)____________ may collect" within our (28)____________ of companies as it (29)____________ to our customers, former (30)____________ and withdrawn or declined (31)____________. One kind of information (32)____________ may share within our (33)____________ of companies but never (34)____________ our business partners is (35)____________ information which is information (36)____________ your credit status or (37)____________ for credit or other (38)____________ products. We obtain credit (39)____________ from your application, such (40)____________ your income and your (41)____________, or from a consumer (42)____________ such as your credit (43)____________ and credit history. We (44)____________ credit information to evaluate (45)____________ eligibility for credit or (46)____________ financial products to verify (47)____________ made by you such (48)____________ your open lines of (49)____________ and to verify credit (50)____________ from another party regarding (51)____________ employment credit or other (52)____________ with you. Information we may share with our business partners. We may (53)____________ with carefully selected business (54)____________ certain information we collect (55)____________ our customers, former customers (56)____________ withdrawn or declined applicants. (57)____________ includes the information we (58)____________ from you on applications, (59)____________ or other forms, such (60)____________ your name, street address, (61)____________ address and telephone number. (62)____________ this way our business (63)____________ can alert you to (64)____________ products and services. We may share the information described on page 1 under "Information we may collect" with our business partners, service providers, and credit bureaus, except that we never share credit information outside our family of companies. [End of the Cloze Test #1] [View Answers to Cloze Test #1] Scoring for Cloze Test #1:
Instructions on Calculating Your Score - Cloze Test #1: What score (percentage correct) did you achieve? Here are instructions on calculating your exact score: The number correct divided by the total number (64).
Example 1: 42 correct divided by the total 64 = .65625 x 100 = 65.625 Rounded off to the nearest percentage point = 66% In this example, you understand the privacy policy. It is well written. Example 2: 22 correct divided by the total 64 = .34375 x 100 = 34.375 Rounded off to the nearest percentage point = 34%
Cloze Test #2. From a Bank's Privacy Policy How we obtain personal customer information. This policy principally governs (1)____________ use of non-public personal (2)____________ information. Non-public personal information (3)____________ defined in applicable law (4)____________ generally means financial information (5)____________ is identified with you (6)____________ is not obtainable from (7)____________ public source. For example, (8)____________ account balance is non-public (9)____________. In contrast, the fact (10)____________ you have a mortgage (11)____________ with us is public (12)____________ because your deed of (13)____________ or mortgage is available (14)____________ public government records. Non-public (15)____________ includes any list, description, (16)____________ other grouping of customers (17)____________ is created using non-public (18)____________ whether or not the (19)____________ also includes public information. (20)____________ example a list of (21)____________ customers that includes current (22)____________ balances would be non-public. (23)____________ information does not include (24)____________ list, description or grouping (25)____________ is created using only (26)____________ information. We obtain personal (27)____________ information primarily from you (28)____________ example when you open (29)____________ account with us or (30)____________ a loan application. We (31)____________ also obtain such information (32)____________ other sources for example, (33)____________ you apply for a (34)____________ we may obtain a (35)____________ report on you and (36)____________ you to authorize us (37)____________ verify your personal financial (38)____________. If we are unable (39)____________ obtain such information from (40)____________ we may be prevented (41)____________ providing you with a (42)____________ and/or may be (43)____________ to terminate an account (44)____________ service that we currently (45)____________ you. We also maintain (46)____________ computer information resulting from (47)____________ experience and transactions with (48)____________. How to limit our use or disclosure of your personal information. As described in the (49)____________, from time to time, (50)____________ will share your personal (51)____________ with affiliated and non-affiliated (52)____________. If you would prefer (53)____________ we not communicate your (54)____________ personal information other than (55)____________ and experience information which (56)____________ are authorized to do (57)____________ the fair credit report (58)____________ among our affiliated companies, (59)____________ that we not communicate (60)____________ non-public personal information with (61)____________ parties for marketing purposes, (62)____________ may instruct us not (63)____________ do so an opt (64)____________ request by calling us (65)____________, visiting your local branch, (66)____________ the form that is (67)____________ as the last pages (68)____________ this policy and mailing (69)____________ to the address indicated (70)____________ by visiting our website. Please allow us up to about 90 days for us to process your request, after receipt. [End of Cloze Test #2] Scoring Cloze Test #2:
Contacting us. Please feel free to contact us with your scores: www.privacyrights.org/qwertyuiopasdfghjkl.php
Additional information about financial privacy policies and the Financial Services Modernization Act, also known as Gramm-Leach-Bliley (GLB):
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| Copyright © 2001-2007. Privacy Rights Clearinghouse/UCAN. For distribution of this fact sheet, see our copyright and reprint guidelines. This copyrighted document may be copied and distributed for nonprofit, educational purposes only.The text of this document may not be altered without express authorization of the Privacy Rights Clearinghouse. This fact sheet should be used as an information source and not as legal advice. PRC fact sheets contain information about federal laws as well as some California-specific information. Laws in other states may vary. Overall, our fact sheets are applicable to consumers nationwide. Privacy Rights Clearinghouse, 3100 - 5th Ave., Suite B, San Diego, CA 92103. Web: www.privacyrights.org |