Is a licensee required to deliver its privacy notice with the short-form initial notice?

The correct answer is that a licensee may provide reasonable means for obtaining the privacy notice instead of delivering it with the short-form initial notice.

In the context of privacy regulations, there is a differentiation between the immediate delivery of notices and the provision of access to those notices. In many regulatory frameworks, a short-form notice may be used as a way to inform consumers about the type of personal information that may be collected and the general purposes for its use. However, detailed privacy notices—which provide more comprehensive information—are not always required to be delivered immediately alongside the initial notice.

Allowing licensees to provide reasonable means for obtaining the privacy notice means they can fulfill their legal obligations by offering ways for consumers to access their privacy notice later—such as via a website or upon request—without the need to hand out the full document at the initial point of contact. This approach balances the need for transparency with the practicality of providing detailed information in a consumer-friendly manner.