Banks share privacy policies, but examine them carefully

                       BY DAN GILLMOR
                       Mercury News

                       Watch your mail carefully for the next few weeks. Financial institutions of all
                       kinds will be telling you, sometimes deviously, how much they care about your
                       privacy.

                       After you stop snickering, start paying attention to what they say -- if you can
                       understand the obscure language some of them will use -- and then take some
                       defensive steps to limit the damage that a new federal law is doing to
                       everyone's privacy.

                       The Financial Services Modernization Act, as its sponsors named this creepy
                       piece of legislation, tore down the Depression-era walls that prohibited some
                       kinds of financial institutions from owning other kinds. Insurance companies
                       couldn't own banks, for example.

                       There were good reasons for the previous policy -- to protect customers --
                       but the powerful financial industry got the old law repealed. Bad idea, but
                       money rules in Congress these days.

                       The lawmakers also looked at data privacy as they considered the bill. As
                       you'd expect, they mostly did the money folks' bidding in this case, too. The
                       act gave the up-and-coming financial conglomerates the right to share your
                       data among all companies under any single corporate umbrella. In other
                       words, your life insurer may soon be able to learn how you spend your money
                       using a credit card issued by a bank owned by the same corporate parent.

                       That was horrible, but the law also gave financial institutions the right to pretty
                       much do as they pleased with your data outside their corporate families --
                       unless you explicitly tell them not do share it.

                       By July 1, all financial institutions have to notify you of your minimal privacy
                       rights. The way they're doing it, as you might expect, raises suspicions about
                       how much they really want you to exercise those rights.

                       First, the privacy advisories are likely to look like junk mail or some stuffer
                       that comes with your monthly bill. If you're like me, you tend to toss out
                       direct-marketing mail and the extraneous stuff that shows up in monthly bank
                       or credit-card statements. I'm sorry to say that we all need to examine
                       everything for the time being.

                       Second, institutions are cloaking the advisories as helpful new guides and
                       services rather than compliance with federal law. The non-profit Privacy
                       Rights Clearinghouse (www.privacyrights.org), based in San Diego, faxed
                       me some examples. US Bancorp proudly declares its ``Consumer Privacy
                       Pledge'' while Wells Fargo and Wal-Mart's credit-card unit call it a ``Privacy
                       Policy.'' Invariably, they tell you how much they value your business and your
                       privacy, but forget to note that they're telling you all this because the new law
                       requires it.

                       Third, they're writing the policies in obscure ways. ``According to the law,
                       these new financial-privacy notices are supposed to be written in a `clear and
                       conspicuous' style,'' says a readability study commissioned by the Privacy
                       Rights Clearinghouse and posted on its Web site. ``This means that the
                       language used should be `reasonably understandable,' a term which is not
                       defined. But based on the readability statistics, none of these 17 notices was
                       even close to meeting that criterion.''

                       Could it be that the financial institutions don't want you to know what they're
                       doing? Or is it just the result of lawyers mucking with disclosure forms? Either
                       way, customers need better disclosure.

                       I strongly advise you to look carefully for these notifications, and then do
                       whatever it takes to inform the financial institutions that your data is not theirs
                       to share. Remember, your inaction is their go-ahead to treat your information
                       as a commodity.

                       Note to readers: If you get a privacy notification that's especially
                       well-disguised or obscurely worded, please send me a copy. I'll create a
                       gallery of the worst offenders and post it online.

                       SPEAKING OF OBFUSCATION: Microsoft's ``Passport'' system, which
                       authenticates users of Hotmail, Microsoft's Instant Messenger software and
                       other products, is also designed to be the entry point to the ``Hailstorm''
                       world of pervasive Web-based services. But our favorite monopolist has
                       come under well-deserved fire for Passport's amazing ``Terms of Use,'' which
                       were so broadly favorable to the company as to be ludicrous.

                       These kinds of documents are common, and outrageous. They give customers
                       few rights, if any, and give sellers practically total license to sell defective
                       goods with impunity.

                       In the Passport case, the terms of use could have been interpreted to mean
                       Microsoft had permission to use its customers' patents and other intellectual
                       property without reimbursement. After a furor, which began when the
                       Register (www.theregister.co.uk), an online publication, reported the terms,
                       Microsoft revised them, saying the document was out of date.

                       The terms are still not what you'd call consumer-friendly. And if you want to
                       learn just how these kinds of terms get written, you may want to stop by
                       Stanford University this afternoon for a colloquium where Jack Russo, a
                       Silicon Valley lawyer who specializes in intellectual-property issues, will
                       deconstruct the Microsoft document from several points of view.

                       Line up the 15 major points in the terms of use, Russo said Tuesday, and look
                       at them from a consumer's side and Microsoft's side. ``They're 180 degrees
                       apart,'' said Russo, of Russo & Hale in Palo Alto.

                       The colloquium is open to the public. It starts at 4:15 p.m. today in the NEC
                       Auditorium, which is located in -- you guessed it -- the Gates Computer
                       Science Building. It will also be available afterward in a streaming media
                       format (www.stanford.edu/class/ee380/).