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Privacy Law
The Gramm-Leach-Bliley Reform Act (Financial Service Modernization Act) was signed into law in November, 1999; and on May 8, 2000, the National Credit Union Association passed the final regulations. Credit Unions have a phase-in period to comply with the regulations and must be in compliance no later than July 1, 2001.
This law requires that prior to sharing nonpublic, personal information about its members with third parties, a credit union must disclose to its members the information it will share. In some instances, the member has the right to direct that the credit union not share his/her nonpublic, personal information with third parties. These are called "opt out" rights.
The law makes exceptions and allows credit union to share information with certain third parties without having to give "opt out" rights to its members. If the credit union shares information with third parties who are affiliates of the credit union, transaction processors, financial institutions, or other service providers, the credit union must still make certain disclosures but does not have to provide "opt out" right to members.
We have conducted an assessment of the data collected from our members and the third parties with which we share information and determined that the nonpublic, personal information is shared only with third parties from the exception list and opt out rights are not triggered.
Attached is the privacy policy, which must be adopted, and the privacy notice, which will be mailed to the credit union’s members with the March statement mailing. The privacy policy and the privacy notice were drafted for credit unions by Trimmier Law Firm using language provided by NCUA.
Privacy Policy
OBJECTIVE:
RESPONSIBILITY:
The Credit Union shall comply with all NCUA Privacy Rules and all applicable state privacy laws affecting us. The Credit Union’s Compliance Officer shall be responsible for ensuring that all Directors, management, and staff are properly trained in the various privacy laws affecting the Credit Union. The Compliance Officer shall continuously monitor privacy regulations. The President/CEO of the Credit Unions shall ensure that the Credit Unions has fully complied with all privacy laws.
PRIVACY PRACTICES
No Credit Union employee shall request information from a member unless that information is necessary to conduct or complete a transaction, process an application, or is for business purposes.
The Credit Union shall only disclose the information it collects from its members and former members to affiliates of the Credit Union, transaction processors, other financial institutions, other service providers of the credit union, and those parties allowed by law, in accordance with 12 CFR Parts 716.13, 716.14, and 716.15.
The Credit Union shall enter into joint agreements with other financial institutions and service providers to ensure that those parties follow our strict confidentiality procedures and do not use our member’s personal information for any purposes other than the purpose of our agreement with them.
The Credit Union shall restrict access to our member’s information to those employees who need to know that information to provide products or services. The Credit Union shall maintain physical, electronic and procedural safeguards that comply with federal and state regulations in order to protect our member’s personal information.
The Credit Union shall create and disclose a privacy notice to all credit union members upon establishing a membership with the Credit Union and at least annually.
Privacy Notice
Jefferson Financial Credit Union is committed to providing you financial products and services to meet your needs and reach your financial goals. We are equally committed to protecting our member’s privacy. You can be confident that your financial privacy is a priority of this credit union. We are required by law to give you this privacy notice to explain how we collect, use, and safeguard your personal financial information.
Information We Collect And Disclose About You
We collect nonpublic personal information about you from the following sources:
- Information we receive from you on applications and other forms;
- Information about your transactions with us or others;
- Information we receive from a consumer reporting agency;
- Information obtained when verifying the information you provide on an application or other forms. This may be obtained from your current or past employers, or from other institutions where you conduct financial transactions.
We may disclose all the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. We do not permit these companies to sell the member information we provide to other parties.
We do not disclose nonpublic personal information about our members and former members to anyone, except as permitted by law.
How We Protect Your Information
We restrict access to nonpublic personal information about you to those employees who have a specific business purpose in utilizing your data. We maintain physical, electronic, and procedural safeguards that comply with federal regulations and leading industry practices to safeguard your nonpublic personal information.
:The Credit Union is committed to meeting all the financial needs of its members without compromising the valued relationship we have with our members. The Directors, management and staff of the Credit Union acknowledge that our member’s trust and confidence in the Credit Union is our highest priority. In their daily transactions and dealings with us, our members furnish us sensitive and confidential information. We are committed to protecting our member’s privacy and it is our stated intent to comply with the NCUA Privacy Rules and other applicable privacy provisions. To ensure that our members continue their trust in our Credit Union, we adopt the following policy:
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