As reported on our blog, last Thursday, the Center for Plain Language held its first ever awards ceremony for the best and worst use of plain language in government and business. One of the two federal government winners of the Center’s ClearMark award, which goes to best uses of plain language, was the Federal Trade Commission’s Model Privacy Form, linked here.
This form shows how a financial company may clearly disclose its use of consumer personal financial information. It presumably is designed to comply with the consumer privacy rules of the Gramm-Leach-Bliley Act.
We note that the form does not use the model language issued by the banking agencies regulations issued pursuant to the GLB Act. Under the current regulations, use of the model language, if accurate, is deemed compliance with the regulation. Thus, most financial companies use the model language (which is why so many privacy statements look and sound similar).
However, if financial companies could obtain some kind of informal clearance to use forms such as the FTC’s - and presumably the agencies would be open to that - we might see companies adopt these more easily to understand privacy and other forms.
