TAILIEUCHUNG - Evolution of a Prototype Financial Privacy Notice: A Report on the Form Development Project

Our research provided significant data that allowed us to gain insight and discern patterns related to participant reactions regarding notice clarity, comprehension, and comparison. 5 This was true across all our testing sessions. A professional transcription service prepared typed transcripts for each interview based on audiotapes. 6 In addition, a notetaker used a structured log to record observations of each testing session. The results were coded and entered into a database using , a qualitative research software package. In our analysis, we examined and used the data collected from each round of testing to revise and refine the prototype. As a result,. | Evolution of a Prototype Financial Privacy Notice A Report on the Form Development Project February 28 2006 . . . K . _ . K l e i m a n n C o m m u n i c a t i o n G r o u p I n c . Executive Summary The Financial Modernization Act of 1999 also known as the Gramm-Leach-Bliley Act GLBA requires financial institutions to provide their customers with initial and annual notices of their privacy policies and practices. The notices must be clear conspicuous and accurate statements of the company s privacy practices and provide a means for consumers to opt out of certain information sharing when they have the right. Soon after the GLBA went into effect in 2001 researchers reported that the privacy notices were too lengthy dense in content and contained complex language they found that most consumers neither read nor understand privacy notices. In response to these findings six of the federal agencies1 that enforce the GLBA initiated a project to explore the development of paper-based alternative financial privacy notices or components of notices that are easier for consumers to understand and use. In September 2004 the six agencies selected Kleimann Communication Group Kleimann for this project entitled the Form Development Project. Our report presents the research-based rationale for a prototype privacy notice iteratively designed over the course of the Form Development Project. The report discusses the methodology used for our qualitative research presents our findings and analysis from eight test sites describes the evolution of the prototype through a 16-month iterative process and outlines key themes that contribute to the success of the project and to the clarity and usability of the prototype. This report completes phase one of the Agencies two-part research project. Phase two a quantitative study to be planned and contracted separately by the Agencies will assess the prototype. 1 The six federal agencies are Board of Governors of the Federal Reserve System Federal

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