Business Affiliate
Definition
An entity that is related to your business through common ownership or control, sharing common branding with your organization. In privacy contexts, business affiliates are important because data sharing with affiliates may constitute disclosure to third parties requiring transparency and potentially consent. However, some privacy laws provide more flexible treatment for affiliate data sharing, recognizing that consumers often understand companies may share data within their corporate family. Under laws like GLBA for financial institutions, sharing with affiliates receives different treatment than third-party sharing. Your privacy policy should clearly identify business affiliates, explain what data is shared with them, and describe how consumers can limit certain types of affiliate data sharing. The key is transparency—consumers should understand the corporate relationships and how their data flows within the business family.
Applicable Laws & Regulations
- 1Gramm-Leach-Bliley Act 15 U.S.C. §6802 - Affiliate sharing provisions
- 2Fair Credit Reporting Act 15 U.S.C. §1681a(u) - Affiliate definition
- 3GDPR Article 4(19) - Group of undertakings