June 18, 2013 - 4:19pm
#1
We have a process when a non-member contacts us about our products/services whereby we step up a "potential member" account and assign it a number. Some accounts do not lead to membership which would then be given designation of a member and assigned a member number (account number) for their accounts. My question is: what regulations apply to (1) when/how we ask for this information, (2) what disclosures do we need to make prior to/during the person giving us the information, and (3) how we store and use it in the future?