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General Policy Statement: The Credit Union recognizes its responsibility to safeguard and protect the nonpublic personal information of our members, and in some circumstances nonmembers. The purpose of this policy is to set forth guidelines under which such information may be shared with third parties, and the circumstances in which we will provide disclosures to our members regarding the sharing of such information. It is the intent of the credit union to abide by all applicable laws and regulations governing privacy, including but not limited to National Credit Union Administration Regulation 716 (Privacy of Consumer Financial Information).
Guidelines:
- COLLECTION OF INFORMATION. The Credit Union will only collect information that is necessary to conduct its business. In the course of delivering products and services, the credit union obtains nonpublic personal information from its members, and in some circumstances from nonmembers. This information is necessary to either comply with a state or federal law or regulation, or to provide effective member services.
- MEMBER ACCESS. The members of the Credit Union will have access to all information the credit union maintains that is related to them individually. Members do have a responsibility to protect their nonpublic private information.
- MAINTENANCE OF INFORMATION. The Credit Union takes reasonable steps and will implement procedures to assure that the member information it gathers is accurate and maintained in a manner to assure its accuracy. In the event inaccurate information is discovered, the credit union will correct the inaccuracy as promptly as possible.
- SALE OF INFORMATION PROHIBITED. It is the policy of the credit union not to sell member information to any third party under any circumstances.
- SHARING OF ACCOUNT NUMBERS PROHIBITED. It is the policy of the Credit Union not to share any account numbers or similar access numbers of its members or nonmembers for use of any marketing purposes.
- DISCLOSURE OF INFORMATION TO THIRD PARTIES. In an effort to provide products and services and comply with state and federal laws and regulations, the credit union does share nonpublic personal information with third parties. Such information sharing is done in compliance with applicable laws and regulations, including providing required disclosures to members that such information sharing takes place.
- RESPONSIBILITY OF THIRD PARTIES. The Credit Union selects its service partners with due diligence and care. If the credit union will share information with a service partner, such service partner will only be approved if it has established privacy policies that are consistent with the privacy policies of the credit union and the laws and regulations governing privacy. Where appropriate, the credit union will protect nonpublic personal information through contractual provisions that prohibit service partners from using information for any other purpose than that for which the credit union provided the information to the service partner. The credit union will consult with legal counsel to assure contracts it enters are in compliance with the laws and regulations governing privacy.
- DISCLOSURE OF INFORMATION SHARING. The Credit Union will provide members, and nonmembers, with initial and annual notices related to privacy policies and practices as required by law or regulation, including, where appropriate, an opportunity to "opt-out" of information sharing. It is the intent of the credit union to properly record and honor all requests from members to "opt-out."
- NON-MEMBER CONSUMER INFORMATION. In some instances, the credit union obtains nonpublic personal information from persons that are not members of the credit union, but are consumers of its products or services. Much of the information the credit union obtains is necessary to complete a transaction or is required for compliance with law or regulation. It is the policy of the credit union to use this information solely for the purpose for which it is obtained either from the consumer directly or from a third party.
- INFORMATION ABOUT FORMER MEMBERS. In the event a person who was a member of the credit union is no longer a member, the credit union will maintain only that information which is necessary to provide products or services that person is a consumer of at the time of becoming a nonmember, as required by law or regulation, and consistent with the Record Retention Policy of the credit union, or for the purpose of contacting the nonmember regarding re-establishing membership in the credit union.
- INTERNAL SECURITY AND PRIVACY. The credit union maintains a comprehensive risk management system to protect the credit union and its members. This plan is intended, in part, to ensure safety and confidentially of member records, protect against anticipated threats or hazards to the security of such records, and protect against unauthorized access to or use of records that could result in substantial harm or inconvenience to a member.