When should the initial privacy notice be provided to a consumer?

The initial privacy notice should be provided to a consumer at the time a customer relationship is established. This is fundamental because it ensures that consumers are informed about how their personal information will be collected, used, and shared from the outset of their interaction with the business or organization. By presenting the notice at this critical moment, consumers can make informed decisions regarding their participation in the relationship, knowing how their privacy will be respected and protected.

Providing the notice before any transaction occurs might seem appealing, but it misses the importance of establishing a clear understanding when the consumer opts into a relationship. Stating that the notice is given only annually would not fulfill the requirement for timely and relevant information, as consumers should be informed at a point when it is most pertinent to their decision-making. Lastly, offering the notice only upon the customer's request would not meet regulatory obligations to inform consumers proactively, making it less effective in promoting transparency and trust. Therefore, delivering the privacy notice at the moment the customer relationship is initiated aligns with best practices and compliance requirements.