As a TPA we receive much confidential information about plan participants. (SS#, address, etc). Does anyone know if it is required or advisable to include some type of disclosure or privacy statement in information we provide to our clients?

Thanks!

WE do, but I think that is b/c we were bought out by a bank and they require us to do everything they do. In this case, that can be a good thing. But they also require us to pass tests on GLB Privacy Act, Bank Secrecy Act, Right to Finanacial Privacy Act, etc...see where I am going with this?

Sorry I am not much help for you.

Advisable or not...Not going to touch that one! I would never say it's a bad idea but then most of the clients I deal with have gotten used to shreading useless privacy notices. Whether they are required or not is another story.

Prior to going to work for a TPA I worked for a bank like Doombuggy did. We sent out Privacy notices to our bank customers but I seem to recall something in GLB that basically said that the privacy rules in GLB did not apply to Trusts, qualified plans, and such because these accounts were already protected by fiduciary rules. Sorry, I can't quote the section of GLB. It was a while ago that I sat on that committee at the bank. We don't send any privacy notices out to our TPA clients.