Guide to United States - GLBA Financial Services Overlay Cookie Consent Compliance

Complete technical implementation guide for United States (federal - financial sector) privacy regulations. Learn about consent requirements, banner elements, record keeping, and technical specifications.

Opt-out Children's Privacy Rules

Summary

This guide provides comprehensive technical implementation requirements for United States - GLBA Financial Services Overlay. Financial institutions must disclose information sharing practices including tracking technologies and provide opt-out mechanisms.

This jurisdiction follows an opt-out consent model, meaning websites can place certain cookies initially but must provide clear mechanisms for users to opt-out of non-essential tracking. Users must be informed about cookies and given easy options to refuse them.

Additional requirements for this jurisdiction include: special protections and consent mechanisms for children's personal data.

Website owners and operators subject to these regulations must implement compliant cookie consent banners, maintain proper consent records, and ensure their tracking technologies respect user privacy choices. This guide outlines all technical requirements needed to achieve compliance.

Key Requirements Overview

Consent Model

Opt-out

Consent Lifespan

12 months

Default State

Mixed

Cookie Walls

Discouraged

Technical Requirements

Prior consent for non-essential cookies

Purpose granularity required

Equal prominence for accept/reject buttons

No pre-checked boxes allowed

Dark patterns prohibited

Proof of consent required

Local storage covered by regulation

Implementation Guidance

Financial institutions must provide clear GLBA privacy notices explaining tracking and data sharing. While GLBA does not require opt-in consent, it mandates disclosure and opt-out for certain third-party sharing. Prudential regulators may scrutinize undisclosed tracking. Best practice: Allow users to opt out of marketing/analytics cookies and clearly disclose tracking in annual privacy notice.

Special Protections

Children's Privacy

Follow COPPA for under-13; treat minors financial data with heightened care.

Sensitive Data

Nonpublic personal information (NPI) including account details, transaction history, credit info must not be shared with third parties without disclosure and opt-out opportunity. Marketing cookies that profile financial behavior should allow opt-out.

Record Keeping Requirements

Required Consent Record Fields

For each consent action, you must maintain records containing:

Timestamp ISO
Opt Out Elections
Privacy Notice Version
Sharing Categories Disclosed

Retention Period: 60 months minimum

Re-consent Trigger: Material Change To Sharing Practices

CookieChimp handles all of this automatically. Our platform maintains comprehensive consent records including all required fields, timestamps, consent strings, IP addresses, user agents, and more. Records are securely stored and easily exportable for compliance audits. Learn more about our consent management

Legal References & Resources

Official legal documents and regulatory guidance for this jurisdiction:

FTC GLBA Privacy Rule

https://www.ftc.gov/business-guidance/privacy-security/gramm-leach-bliley-act

GLBA Safeguards Rule

https://www.ftc.gov/business-guidance/resources/financial-institutions-customer-information-complying-safeguards-rule

Legal Disclaimer: For engineering implementation guidance only. Not legal advice. This guide provides technical implementation guidance only and should not be considered legal advice. Privacy laws are complex and frequently updated. We recommend consulting with qualified legal counsel to ensure full compliance with applicable regulations.