Richard Albee, Executive Vice President Mary Russell, Senior Vice President, Corporate Systems and Project Support Citizens Banking Corporation
		Michigan-based Citizens Banking Corporation is a diversified financial services company with banking assets of $7.9 billion and $3.8 billion in trust assets. With more than 200 branches throughout Michigan, Illinois, Wisconsin, Minnesota, and Iowa, Citizens provides a full range of commercial, consumer, mortgage, trust, and financial planning services to both companies and individuals. Like all US banks, Citizens was facing the July 1, 2001 deadline to comply with the Gramm-Leach-Bliley Act of 1999, which requires banks to establish and implement a policy that ensures the security and confidentiality of customers' private financial information. This policy must also include a mechanism to allow customers to "opt-out" of having their information shared by their bank. The timing was not good for Citizens, which was deeply involved in several major projects, including computer conversions of twenty-four separate banks. To comply with the statute, the bank would have to assess the security policies and procedures in every department and make a number of major operational, training, and management changes. Needing a vendor it could rely on to deliver solid results on time and within budget, Citizens retained ADS, which was already working with the bank on its conversion projects. Consultants from ADS' IT Strategy and Consulting Practice began by assessing literally every function within the bank's operations where customer information was stored or handled. The team began work in August 2000, evaluating all thirty departments within the Citizens organization and collecting detailed information about the customer data in each department, including how it was managed and shared with other departments. Because Citizens had decided to follow an "opt-out" policy, giving customers the choice of having some, all, or none of their financial information shared by the bank, ADS proceeded to develop the specific processes needed to support the policy in all departments. An ADS systems consultant then worked with Citizens staff and its processor Metavante to install the system enhancements necessary to ensure that each customer's "opt-out" choices would be carried out appropriately and consistently. In addition, ADS developed sets of detailed training materials, each one tailored to the level of customer contact of a particular position in the bank, from tellers and customer service representatives to back office staff to executives. Finally, ADS assisted in preparing the actual privacy policy statement for communication with all bank customers. By December, ADS had completed its work—well ahead of the Gramm-Leach- Bliley deadline. The resulting privacy policy meets the needs of Citizens' customers without unduly restricting bank operations—and it enabled Citizens' heavily committed staff to focus its efforts on more strategically important activities.