Hi David,
I'm not sure the privacy rule applies in the case of the thin title plant or online public documents. The following is taken from the FTC facts for business for complying with the Gramm-Leach Bliley Act.
The privacy notice must be a clear, conspicuous, and accurate statement of the company's privacy practices; it should include what information the company collects about its consumers and customers, with whom it shares the information, and how it protects or safeguards the information. The notice applies to the "nonpublic personal information" the company gathers and discloses about its consumers and customers; in practice, that may be most - or all - of the information a company has about them. For example, nonpublic personal information could be information that a consumer or customer puts on an application; information about the individual from another source, such as a credit bureau; or information about transactions between the individual and the company, such as an account balance. Indeed, even the fact that an individual is a consumer or customer of a particular financial institution is nonpublic person information. But information that the company has reason to believe is lawfully public - such as mortgage loan information in a jurisdiction where that information is publicly recorded - is not restricted by the GLB Act.
The full Fact Sheet can be found at http://www.ftc.gov/bcp/conline/pubs/buspubs/glbshort.htm
Charles W. Skinner
Manth-Brownell Inc.
www.manth.com
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