Robinhood collects highly sensitive identity and financial data including your Social Security number, passport number, driver's license number, bank account numbers, and credit card numbers as part of its standard account and service operations.
This analysis describes what Robinhood's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Collection of Social Security numbers and government-issued ID numbers alongside financial account numbers represents a concentration of data that, if improperly disclosed, could enable identity theft or financial fraud; users should understand the breadth of sensitive identifiers collected.
The updated privacy policy reorganizes how Robinhood discloses its handling of financial information, now grouping GLBA-regulated disclosures by individual service entity with updated reference links…
The policy states Robinhood collects Social Security numbers, passport numbers, driver's license numbers, bank account numbers, and credit card numbers, meaning a broad set of identity and financial credentials is held on file in connection with Robinhood accounts.
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"Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Personal information described in the California Customer Records statute, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.— Excerpt from Robinhood's Robinhood Privacy Policy
1) REGULATORY LANDSCAPE: Collection of Social Security numbers and government-issued ID data implicates the GLBA Safeguards Rule (enforced by the FTC and CFPB for non-bank financial institutions), the FCRA for credit-related data, and state data breach notification laws (e.g., California, New York SHIELD Act). The FTC's Safeguards Rule requires covered financial institutions to implement a written information security program protecting nonpublic personal information including SSNs and account numbers. 2) GOVERNANCE EXPOSURE: High. The aggregation of SSNs, passport numbers, financial account numbers, and credit card numbers in a single platform creates significant data security and breach notification obligations. Any unauthorized disclosure of this data would trigger multi-state and potentially federal breach notification requirements. 3) JURISDICTION FLAGS: All US states have breach notification laws applicable to SSNs and financial account numbers. Illinois, New York, and California have heightened requirements. Financial data is subject to FTC Safeguards Rule obligations at the federal level. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party service providers with access to SSNs or financial account numbers must be assessed under the FTC Safeguards Rule's vendor oversight requirements. Data processing agreements should specify permissible uses and security standards for these categories. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that data minimization practices limit SSN and government ID collection to regulatory necessity (e.g., KYC, AML), that these categories are not included in any advertising or analytics data flows, and that data retention schedules comply with applicable regulatory minimums and maximums.
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Collection of Social Security numbers and government-issued ID numbers alongside financial account numbers represents a concentration of data that, if improperly disclosed, could enable identity theft or financial fraud; users should understand the breadth of sensitive identifiers collected.
The policy states Robinhood collects Social Security numbers, passport numbers, driver's license numbers, bank account numbers, and credit card numbers, meaning a broad set of identity and financial credentials is held on file in connection with Robinhood accounts.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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