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This policy reaffirms and formalizes our bank's realization of and respect for the privacy expectations and rights
of our customers regarding financial information and other related information, which the bank has or gathers in
the normal course of business. It is intended to provide guidance to bank personnel as well as assurance to our
customers. We will also, of course, act in compliance with all applicable laws and regulations.
Employee: For the purpose of this policy, "employee" includes all directors, officers, and employees of the bank as well as any attorney, agents, or outside vendors, who become privy to customer information.
Consumer: An individual who obtains or has obtained a financial product or service from a bank that is to be used primarily for personal, family, or household purposes, or that individual's legal representative. An example of a consumer would be a loan applicant. A consumer is not necessarily a customer.
Customer: A person who has established a "continuing relationship" with our bank. (For example, an approved loan applicant who signs a note would be a customer)
Nonpublic personal information: Personally identifiable information relating to a consumer, except when there is a reasonable belief that the information is publicly available. For example, the fact of a customer relationship with the bank, presumably, would be nonpublic personal information. It is only if personally identifiable information relating to a consumer is publicly available, that such information is excluded from nonpublic information.
Publicly available information: Any information that a bank has a reasonable basis to believe is lawfully made available to the general public from Federal, State, or local government records; widely distributed media; or disclosures to the general public that are required to be made by Federal, State, or local law. (For example, a published telephone directory, or the public record of real estate transactions)
The Board of Directors has the ultimate responsibility to appropriately establish and maintain this policy and assure that is being observed in the daily operation of the bank. The Compliance Officer is responsible for carrying out this policy and making recommendations of any changes to the board of directors as necessary.
Customers of our bank are entitled to the absolute assurance that the information concerning their financial circumstances and personal lives, which the bank has obtained through various means, will be treated with the highest degree of confidentiality and respect. Certain expectations of privacy also contain legal rights of customers which are either granted or confirmed to them through various federal and state laws and regulations. All employees are directed by this policy to assure customers of the bank's commitment to preserving the privacy of their information.
It is the policy and practice of the bank to collect, retain and use information about consumers and customers (both individual and corporate) only where the bank reasonably believes the gathering of such information would be useful and allowed by law to administer the bank's business and/or to provide products, services or opportunities to its customers.
Executive management is directed to establish procedures to ensure that, to the extent practicable, all customer information is accurate, current and complete in accordance with reasonable commercial standards. The bank will respond promptly and affirmatively to any legitimate customer request to correct inaccurate information, including forwarding of corrected information to any third party who had received the inaccurate information. The bank will further undertake to record that the customer requested such corrective action and follow up with any third party to ensure that they have processed the correction.
Executive management will take all steps necessary to ensure that only employees with a legitimate business reason for knowing personally identifiable customer information shall have access to such information. To the extent practicable, access will be limited by computer access codes and granting limited access to areas in which sensitive customer information is retained. Employees will be informed at the time of their initial employment of these standards and periodically reminded of these standards during training sessions at least
once during each calendar year. Willful violation of this element of this policy will result in disciplinary action against the offending individual. Inadvertent violations will be dealt with in a manner to ensure that such violations are not repeated.
The bank will not, except in cases allowed or required under the law, reveal specific information about customer accounts or other nonpublic personal information to any nonaffiliated third parties unless the customer has been provided the required privacy disclosures and is given the opportunity to decline or "opt out."
If the bank is requested to provide personally identifiable to a third party and that request is in all respects consistent with other elements of this policy, the bank will accede to the request only if the third party agrees to
3 adhere to similar privacy principles, no less stringent than set forth in this policy, that provide for keeping such information confidential.
Disclosure of the privacy notice (Appended as a part of this policy) shall be provided to customers initially and then annually thereafter. A notice of the right to "Opt Out" will accompany each privacy notice, unless our bank shares nonpublic personal information only with entities in the three categories of exceptions listed below. If our bank does share nonpublic personal information only within the three categories of exceptions, a simplified privacy notice will be provided to customers.
The notice may be delivered by hand, by mail, or electronically, as specified in the pertinent banking regulation. If the notice is provided electronically, the consumer must be required to acknowledge receipt as a necessary condition for obtaining a financial product or service.
Attached will be our actual disclosure we deliver to consumer customers at deposit account opening and loan origination and annually by direct mailing or by using the alternate delivery method (notice on statements and website).
12 CFR 216.13
The opt out requirements do not apply if our bank chooses to provide nonpublic personal information about a consumer to a nonaffiliated third party to perform services for the bank or functions on the bank's behalf, if our bank provides the initial notice as required and enters into a contractual agreement with the third party that requires the third party to maintain the confidentiality of the information to at least the same extent that the bank must maintain that confidentiality and limits the third party's use of the information solely to the purposes for which it is disclosed or as otherwise permitted.
12 CFR 216.14
The requirements for initial notice, for opt out, and for service providers and joint marketing do not apply if the bank discloses nonpublic personal information:
Other Exceptions to Notice and Opt Out Requirements CFR 216.13
There are additional exceptions to the opt out requirements. The requirement for initial notice, for opt out, and for service providers and joint marketing do not apply when a bank discloses nonpublic personal information in the following circumstances:
Executive management is directed to provide a copy of this policy to all bank employees and to obtain a receipt from each employee acknowledging that fact. After any amendments or modifications to this policy have been duly adopted, a copy of the amended policy will also be given to each employee, again acknowledged by receipt.
At least once during each calendar year, the bank will conduct a meeting of all employees during which matters affecting customers' rights to privacy will be discussed. Such meetings will include discussion on the following:
Executive management will maintain a separate file for the purpose of retaining any customer complaints, which relate to this policy. The information regarding any complaint should include the exact nature of the complaint, describe the corrective actions taken, and confirm that the corrective actions resolved the complaint.
Executive management will make an annual report to the board concerning customer complaints, which shall include the frequency and nature of such complaints and corrective actions taken. Complaints of a nature sufficient to present a risk of regulatory enforcement action and/or civil money penalties are required to be reported if and when they occur.
The board of directors will review this policy at least once each year and make any revisions and amendments it deems appropriate. The Compliance Officer will be responsible for suggesting more frequent revisions as situations or changes in laws or regulations dictate.
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
Citizens Deposit Bank
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We collect your personal information, for example, when you
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
Companies related by common ownership or control. They can be financial and non-financial companies.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.