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KENNEDY V.A. EMPLOYEES FEDERAL CREDIT
UNION PRIVACY POLICY
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GOAL: To protect member's personal information while making available financial
products and services that meet their needs and enable them to
reach their financial goals.
OBJECTIVES:
1. To ensure member's personal information stored in files and on
computer is protected by strong security controls.
2. To protect member confidentiality by restricting personal infor-
mation to those employees that need to know that information.
3. To only share information when necessary to administer the
products and services we provide, when required to do so by
law or government, or when we partner with others to offer a
broader array of products and services.
COMPLIANCE: The Credit Union will comply with the privacy rules as required
under the Financial Services Modernization Act.
RESPONSIBILITY: Internal responsibility for compliance shall rest with the
Manager and Assistant Manager of the credit union.
DISCLOSURE
KVAEFCU'S PRIVACY NOTICE WILL BE CONSPICUOUSLY POSTED
IN THE CREDIT UNION OFFICE BEGINNING 03-31-2001.
INITIAL DISCLOSURE:
Primary members will receive a privacy disclosure in their March 31,
2001 statement, joint owners will not receive a separate notice.
SUBSEQUENT DISCLOSURE:
Effective March 31, 2001, any new member to the Credit Union will
receive a privacy disclosure. Effective March 31, 2001, any non-member
being added to an account, cosigning on a KVAEFCU loan, or
KVAEFCU Mastercard account will be given a disclosure at the time the
transaction is completed, no annual privacy notice will be sent.
ANNUAL DISCLOSURE:
Primary members will receive a current privacy notice every twelve (12)
months beginning in 2002, joint owners will not receive a separate notice.
FORMER MEMBERS:
KVAEFCU will not disclose nonpublic information or send annual privacy
notices to former members.
PROMOTIONAL MATERIALS, NEWSLETTER ETC:
KVAEFCU will obtain written permission before using any photograph,
likeness, or name that may disclose the fact that a person is a credit union
member.
"EMPLOYEES MUST MAINTAIN THE CONFIDENTIALITY OF ALL MEMBERS INFORMATION EXCEPT AS REQUIRED TO DO THEIR JOBS, OR AS REQUIRED BY LAW."
DIVULGING MEMBER'S PRIVATE INFORMATION MAY RESULT IN DISCIPLINE UP TO AND INCLUDING TERMINATION OF EMPLOYMENT.
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INTERNAL PROCEDURES
A. NEW MEMBERS
1. When an eligible person applies for membership in the Credit
Union, it is the employee's responsibility to fully explain KVAEFCU's
privacy policy.
2. Emphasis shall be placed on the fact that security controls are in
effect for the protection of members and are not intended to cause
inconvenience to anyone.
MEMBER INFO:
1. In light of the new privacy rules and regulations, members may ask to
review their Credit Union file. It shall be KVAEFCU's policy to allow the
member to see any and all information, example; membership card,
loan file, MasterCard file etc.
1. Member must request in writing and schedule a time with
KVAEFCU management to come into our office for the review.
2. Member must tell us, at the time the appointment is scheduled,
what he/she wishes to review.
3. Information requested will be pulled and the member allowed to
review the information in the presence of KVAEFCU management
The member will not be allowed to copy certain documents, such
as credit reports, or to remove information or documents from the
Credit Union office, for this reason, KVAEFCU management will
remain with the member at all times.
B. TELEPHONE TRANSACTIONS:
1. Account information and transactions, such as transfers and
check withdrawals, may be handled by telephone if the identify
and the authority of the person requesting the information or
transaction can be verified.
C. MAIL:
1. Check withdrawals or other personal information will be
mailed to the address on the computer unless otherwise
approved by manager or assistant manager.
2. Address changes must be in writing, signed by the member,
fax is acceptable.
3. No information will be given to mortgage companies etc.,
without a signed authorization from the member.
D. CREDIT INFORMATION:
1. KVAEFCU will report members" loan information and
derogatory information, such as negative accounts, to the
major credit bureaus.
2. KVAEFCU will give loan payoffs and reciprocal credit
information to other lending or collection agencies for the
purpose of skiptracing etc, if the identity of the agency can
be verified to our satisfaction.
E. MERCHANT CHECK VERIFICATION:
1. KVAEFCU will answer merchant check verifications with
the following information:
* Member Name
* Micro number or Social Security Number
* Amount of check
* Check number series
* If the merchant is seeking only verification that the
account is open, the request must be made in
writing signed by the member.
F. PRE-TEXT CALLING:
1. KVAEFCU will not engage in any pre-text calling to obtain
information about missing members. Example, skip- tracing --
--even if an outside agency is employed.
2. Any outside agency employed or partnered with KVAEFCU will be
required to have, as part of their contract, a statement stating they will
not use or attempt to use pre-text calling.
G. SECURITY OF DATA PROCESSING SYSTEM:
1. Access to member information stored in files and on computer
will be on a "need to know basis."
2. Internal security levels are set for each job description and will
allow employees to see and perform only functions needed.
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