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Valley Savings Bank Financial Privacy Policy Purposes and Objectives: This policy reaffirms and formalizes Valley Savings 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 our bank personnel as well as assurance to our customers. We will also, of course, act in compliance with all applicable laws and regulations. Definitions Employee: For the purpose of this policy, it includes all directors, officers, and employees of Valley Savings Bank as well as any attorneys, agents, or outside vendors, who become privy to customer information. Consumer: An individual who obtains or has obtained a financial product or service from Valley Savings 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 Valley Savings Bank. (For example, an approved loan applicant who signs a note would become 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.) Responsibility The Board of Directors has the ultimate responsibility to appropriately establish and maintain this policy and assure that it is being observed in the daily operations of the bank. The Chief Operating Officer is responsible for carrying out this policy and making recommendations to the board of directors as to necessary or desirable changes to the policy of Valley Savings Bank. Privacy Principles Valley Savings Bank recognizes the following eight elements of its privacy policy, which have become standard within the banking industry:
Recognition of Customer's Expectation of Privacy Customers of Valley Savings 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 Valley Savings Bank's commitment to preserving the privacy of their information. Valley Savings Bank will post a notice in all banking offices and its Web site which contains an abbreviated version of this policy. That notice is included as part of this policy and is designed to be both a posted notice and a direct disclosure to customers under circumstances described later in this policy. Use, Collection and Retention of Consumer Information It is the policy and practice of Valley Savings Bank to collect, retain and use information about consumers and customers (both individual and corporate) only where Valley reasonably believes the gathering of such information would be useful and allowed by law to administer Valley's business and/or to provide products, services or opportunities to its customers. Maintenance of Accurate Information Management is directed to establish procedures to ensure that, to the extent practicable, all customer financial information is accurate, current and complete in accordance with reasonable commercial standards. Valley Savings 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 such corrective action was requested by the customer and follow up with any third party to ensure that they have processed the correction. Limitation on Employee Access 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. Protection of Information Valley Savings Bank will maintain appropriate security standards and procedures to prevent unauthorized access to customer information. Such procedures should prevent access by not only unauthorized employees, but others as well. Such others include but are not limited to, all non-employees with otherwise legitimate reasons for being on Valley Savings Bank's premises, computer hackers, and any intruders on Valley's premises. General Restriction on the Disclosure of Customer Information Valley Savings 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. Business Relationships with Third Parties If Valley Savings Bank is requested to provide personally identifiable information to a third party and that request is in all respects consistent with other elements of this policy, Valley will accede to the request only if the third party agrees to adhere to similar privacy principles, no less stringent than set forth in this policy, that provide for keeping such information confidential. Valley Savings Bank will not enter an agreement with any entity covered under the first category of exception, listed below, without first requiring the entity to maintain the confidentiality of the information to at least the same extent that the bank must maintain that confidentiality and limit the third party's use of the information solely to the purposes for which it is disclosed or as otherwise permitted by law. Disclosure of Privacy Principles to Customers 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 within the three categories of exceptions, listed below. In the future Valley Savings Bank may disclose nonpublic personal information to nonaffiliated third parties to provide our customers with information about additional products and services. A notice will be provided to consumers/customers before sharing such information. 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. If a customer has a joint account, an opt out instruction given by one of the participants of this account will affect all participants of the account. Exceptions to the Opt Out Requirements for Service Providers and Joint Marketing The opt out requirements do not apply if Valley Savings 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 Valley Savings 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. Exceptions to the Opt Out Requirements for Processing and Servicing Transactions 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 There are additional exceptions to the opt out requirements. The requirements 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:
For the following protective or legal situations:
Employee Education and Training 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 customer's rights to privacy will be discussed. Such meetings will include discussions on the following:
Record Keeping and Reporting 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. 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. Review of Policy The board of directors will make a review of this policy at least once each year and make any revisions and amendments it deems appropriate. The Chief Operations Officer will be responsible for suggesting more frequent revisions as situations or changes in laws or regulations dictate.
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