Privacy Policy

The purpose of this policy is to adhere to the privacy requirements of the Graham-Leach-Bliley Act and privacy regulations set forth by the NCUA.

To assure the continued privacy and confidentiality of our member's person financial information, the Credit Union observes the following procedure:

Information We Collect
We collect nonpublic information about members from some or all of the following sources:
• Information we receive from members on applications or other forms, such as a member's name, address, social security number, assets and income.
• Information about a member's transactions with us, our affiliates, or others such as a member's account balance, payment history, parties to transactions and credit card usage.
• Information we receive from a consumer reporting agency, such as a member's creditworthiness and credit history.

Information We Disclose
We may disclose all of 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 may also disclose information about a member under other circumstances as permitted by law.

Our Security Measures
We restrict access to nonpublic information about members to those employees who need to know that information to provide products or services to members. We maintain physical, electronic and procedural safeguards that comply with Federal Regulations to guard member nonpublic person information.
In addition to the above policy the following items have been established to ensure that the Credit Union and the vendors that the Credit Union works with are following the Privacy Act.

The VPO is responsible for developing and updating notices as well as ensuring the notices are properly distributed.

It is the President's responsibility to make recommendations to the Board of Directors regarding vendors and information shared. It is the Board's responsibility to approve any new vendors and what information will be shared.

The Credit Union will require all new contracts to contain a confidentiality clause specifically identifying how the vendor will use the shared information.

As stated in the Privacy Policy, the Credit Union recognizes that there are exemptions to the privacy policy which are not covered by the law and /or the regulation.

In the process of developing a web site, a specific privacy policy will be drafted and adopted with regard to the Credit Union's information gathering techniques.

Privacy Procedure Outline
The purpose of this procedure is to ensure that all of the Credit Union's employees understand the Privacy Policy and their requirements and to make sure the Credit Union complies with the regulation.

The policy covers all member accounts and pertains to all personal financial information collected from the member.

The Credit Union recognizes the need to share information. However, we are committed to limiting the information shared on any individual member to a need to know basis. In dealing with vendors, only the specific information needed to process the member's request will be obtained and passed on to a third party. Internally, staff members will have access to a member's information on a need to know basis.

The initial notice will be sent in the lst Quarter 2001 newsletters. The newsletter is sent to all members. This notice will satisfy the regulatory requirements. On an ongoing basis, all members will receive a privacy policy notice at the time they open their new account. As soon as the current supply is used, the policy will be printed on the Truth in Savings disclosures.

Each employee will go through privacy policy training session. Each employee will be given a copy of the policy, the procedure and instructions regarding the serious nature of the policy and the need to adhere strictly to the policy.

With the addition or deletion of vendors the exchange of information will be initiated or terminated as required. The Board will be required to approve all new vendor relationships.

New or additional disclosures will not be made to an existing member requesting additional products or services.

The annual notice will be made in the 1st Quarter newsletter on an annual basis.

Copies of the policy can be requested at any branch office by contacting the member service officer.

Since the Credit Union does not have any vendor relationships requiring an "opt-out" clause, the Credit Union will not make this option available to the membership. The "opt-out" clause will be reviewed with staff allowing them to understand what the option is and how it effects other financial institutions.

Employee training regarding the Credit Union's Privacy Policy will be conducted on an ongoing basis.