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Tags:

Mixed Methodology Research, Consumer Protection, Privacy Notice, Federal Regulation Compliance

Financial Privacy Notice

The importance of testing with consumers to create a clear privacy notice

Background:

Privacy regulations introduced by the Federal Trade Commission obligate financial services companies to let consumers know the requirements and restrictions on their right to disclose nonpublic personal information to nonaffiliated third parties. Kingsley-Kleimann worked across agencies including the FTC, Board of Governors of the Federal Reserve System, FDIC, NCUA, Office of the Comptroller of the Currency, and the SEC to develop the disclosure consumers receive.

What We Did:

  • Worked with Interagency team from six federal agencies to bring consensus on the design of the Financial Privacy Notice.

  • Used mixed methodology of 2 focus groups, 11 preference interviews, and a total of 35 one-on-one cognitive interviews across 5 locations.

  • Developed a disclosure that was clear, conspicuous, technically accurate yet still allowed readers to understand what a financial institution does with their personal information.

Impact:

  • Consumers are interacting with the Model Privacy Notice in nearly every financial institution in the U.S. — car finance companies to major credit cards like Visa, to major banks like Citibank, to credit unions and community banks.

  • All federal agencies were able to align on the direction of the privacy notice due to mixed methodology testing which provided clarity on how everyday consumers would interpret and understand the privacy notice.

  • Consumers across the U.S have benefited from the five major findings from our research:

    • Keep it simple

    • Good design matters

    • Careful design decisions ensure neutrality

    • A “whole to part” design is critical to comprehension

    • Standardization is highly effective

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