The collection of personal and financial information is nothing new to the banking industry. Various regulations require that certain information be obtained (i.e. tax identification numbers, fair housing information, etc.). In addition, prudent loan underwriting and mailing information must be obtained to assure operating safety and soundness and to deliver important documents to our customers. The collection of information may be directly within bank means or indirect through third party vendors such as credit bureaus. In addition, information can be collected by a variety of methods; mail, in person, or electronically.
The bank will only collect information in the normal course of business to conduct the activities associated with commercial banking. The bank will collect, retain and use information about individual customers only as allowed by law to administer our business and where we reasonably believe it would be useful to provide products, services and other opportunities to our customers. Unless required by law, we will not collect information on race, martial status, national origin or other protected classes of individuals.
Some of the key measures taken by Farmers State Bank to protect your information are summarized below in our Privacy Notice.
We collect nonpublic personal information about you from the following sources:
- Information we receive from you on applications or other forms;
- Information about your transactions with us or others; and
- Information we receive from a consumer reporting agency.
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law.
If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic person information.
Annual Privacy Notice Policy
Statement of Information to be disclosed
This bank discloses, and wishes to reserve the right to disclose, nonpublic personal information about its customers and/or former customers to nonaffiliated third parties
This Policy is limited to only those consumers and customers who obtain a financial product or service from the bank that are to be used primarily for personal, family, or household purposes.
Definitions used in this policy are consistent with terms used in the statutory definitions and regulatory issuance’s related to consumer privacy in the financial services industry.
Privacy notices were created as required by law, the privacy notice accurately summarizes the bank’s privacy principles and practices.
The privacy note parallels the internal operational policies, procedures, and controls of the bank. The privacy notice is available on the bank’s web site.
Communication the Initial Privacy Notice
In the case of a consumer or customer, the initial privacy notice will be provided when he approaches the bank to obtain a product or service from the bank.
Method of Delivery
The bank will provide the required notice such that the consumer or customer can reasonably be expected to receive the actual notice in writing and be able to retain it. The bank may reasonably expect that a consumer or customer has received the privacy notice and can retain it if the privacy notice is:
- Handed in printed format to the consumer or customer; or
- Mailed to the consumer’s or customer’s last known address.
Oral description of the notice is not deemed adequate. Accordingly, the bank’s staff may not provide the initial notice required by orally explaining the details of the notice, either in person or over the telephone.
Providing the Annual Customer Privacy Notice
On an annual basis, the bank provides a customer privacy notice. This notice is provided in a clear, conspicuous manner to each customer/consumer. However, it is acceptable to provide a single notice for joint accountholders. Following the initial privacy given to each customer, the bank has chosen to provide the annual customer data privacy notice on or before December of each year beginning December 2002.
Privacy Notice Content
The privacy notice provided initially and annually to all consumers and customers contains the information to the extent required by law in a clear, conspicuous manner.
The bank will not be able to directly, or through any affiliate, disclose any nonpublic personal information about a consumer or customer to a nonaffiliated third party unless:
- The bank has provided the consumer or customer with an initial notice
- The bank has provided to the consumer or customer an opt-out notice.
- The bank has given the consumer or customer a reasonable opportunity, deemed to be 30 days after the notice has been mailed or hand-delivered, to opt out of the disclosure before the institution discloses the information to the nonaffiliated third party.
- The consumer or customer does not opt out.
A consumer or customer of the bank has the right to direct the bank not to disclose nonpublic personal information about the consumer or customer to a nonaffiliated third party, except in those situations already permitted by law.
When the right to opt out is allowed, the bank will provide to each consumer or customer a clear and conspicuous notice that accurately explains the right to opt out.
Opt-out Exceptions for Service Providers
A customer or consumer will not have the right to opt out if the bank provides nonexempt nonpublic personal information about a consumer or customer to a nonaffiliated third party to perform services for the bank of functions on the bank’s behalf, if the bank:
- Provides the initial required notice
- Enters into a contractual agreement with the third party that prohibits the third party from disclosing or using the information other than to carry out the purposes for which the bank disclosed the information.
- Provide the consumer or customer with a revised notice that accurately summarizes the bank’s revised policies and practices.
- Provide the consumer or customer an opt-out notice with the revised notice.
- Given the consumer or customer a reasonable opportunity, deemed to be 30 days after the notice has been mailed, hand-delivered, or delivered electronically, to opt out of the disclosure before the institution discloses the information to any affiliate or nonaffiliated third party.
- The consumer or customer does not opt out.
Until such time that the bank has followed the procedure, it may not directly or through any affiliate, disclose any nonpublic personal information about the consumer or customer to any affiliate or nonaffiliated third party other than as detailed in the initial notice provided by the bank to the consumer or customer.
Information the Bank can disclose to affiliates and nonaffiliated third parties
The bank is permitted by law to disclose certain information to affiliates and nonaffiliated third parties even if a consumer or customer opts out. The bank can disclose publicly available information, as defined by law. The bank can also disclose “exempt” nonpublic personal information under certain circumstances and reasons found in the regulation.
If one or more customer jointly obtain a financial product or service from the bank, the bank may satisfy the privacy notice requirements by providing one notice to those jointly.
Limitations on Redisclosure and/or Reuse of Information
If the bank receives nonpublic personal information from a nonaffiliated financial institution under an exception, the bank’s disclosure and use of that information is limited in use, as stated in the regulation.
If the bank receives nonpublic personal information from a nonaffiliated financial institution other than under an exception, then the bank may disclose the information as per the regulation.
If the bank discloses nonpublic personal information to a nonaffiliated third party under an exception, the third party may disclose and use that information according to the regulation.
If the bank discloses nonpublic personal information to a nonaffiliated third party other than under an exception, the third party may disclose the information according to the regulation.
Limits on sharing account number information for marketing purposes
The bank must not directly or through an affiliate, disclose, other than to a consumer reporting agency, an account number or similar form of access number or access code for a consumer’s or customer’s credit card account, deposit account, or transaction account to any nonaffiliated third party for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer or customer.
Certain exemptions to this prohibition exist under the privacy regulations.
Record Retention Information/Security
The bank will restrict access to nonpublic information about its customers to those employees who need to know that information to provide products and services to the customer. The bank will maintain physical and electronic safeguards that comply with federal standards to guard the customer’s nonpublic personal information.
Senior Vice President Curtright will be responsible for training and reviewing this policy with the staff of the bank.
Audit and Internal Compliance
This addenda will be reviewed and revised, if need be, annually as part of the bank’s existing director’s audit.
Security is one of the greatest concerns about banking over the Internet. Customers want to know that their account numbers cannot be stolen, that their personal confidential information is kept private, and that their accounts cannot be accessed by any unauthorized persons. That's why The Farmers State Bank's Online Banking service has installed the very latest in security technology.
When you log onto The Farmers State Bank's Online Banking service you are required to use an Access Id and a password. After attempting to log in with an incorrect password three times, your account becomes locked out. Additionally, the Online Banking service has a time-out feature: If you do not make a request to the server within ten minutes, your Online Banking session will be terminated and you will have to log in again.
We share your concerns about security, and it is our top priority in bringing you the convenience of Online Banking. All of our systems and procedures have been selected to give you the highest level of security possible. You can rest assured your most private financial information will remain that way.
YOU CAN HELP IN THE LINE OF DEFENSE BY DOING THE FOLLOWING:
- Use Strong Passwords – Choose passwords that are difficult or virtually impossible to guess. Don't use the same password for your banking services that you use for other accounts or services.
- Make Backups of Critical Data Regularly – Backups should be made at least once each day. Larger organizations should complete full backups weekly and incremental backups every day. Don't forget to verify your backups at least once a month.
- Use Virus Protection Software – Make sure you have reliable software protection installed on your computer. Check daily for updates to the software and then perform periodic scans of all files on your computer.
- Use a Firewall as a Gatekeeper Between Your Computer and the Internet – Firewalls are usually software products. They are essential for those who keep their computers online through the popular DSL and cable modem connections but they are also vulnerable for those who still dial in.
- Don't Keep Your Computer Online When You Aren't Using It – Either disconnect or physically unplug the connection.
- Don't Open E-mail Attachments from Strangers – Regardless of how enticing the subject line or attachment may be, always be suspicious of any unexpected email attachment from someone you don't know. It may have been sent without the person's knowledge from an infected computer.
- Protect Yourself against E-Mail Fraud – Internet "phishing" scams are one of the fastest growing frauds today. Phishing typically involves a bogus e-mail message that uses legitimate materials, such as a company's logo or web site graphics. They attempt to entice you to provide personal confidential information, such as a Social Security Number or Account Number.
STOP – Do not immediately respond to a suspicious email, even if they say it is urgent.
READ – Carefully read the email and ask yourself why someone needs this information.
CALL – Make a telephone call to the organization requesting the information. USE a number you know is correct for that organization. DO NOT USE one supplied in the email.
Every effort has been made by Farmers State Bank to give accurate and reliable information in Farmers State Bank's website. Please be aware that due to the possibility of human and mechanical errors, as well as other factors, Farmers State Bank is not responsible for any errors or omissions confined herein.
All information in Farmers State Bank website is provided "as is," without warranty of any kind. Farmers State Bank makes no representations and specifically disclaims any express or implied warranties to users or any third parties, including but not limited to, warranties as to accuracy, timeliness, completeness, merchantability, or fitness for any purpose. The content of the website may not be used for commercial or non-commercial use without the express written consent of Farmers State Bank.
Farmers State Bank shall not be liable under any circumstances to users and/or any third parties for indirect, consequential, incidental or punitive damages as a result of using the website. Even if Farmers State Bank is advised of the possibility of such damages, Farmers State Bank shall not be liable.
Farmers State Bank's website may include access to external websites, known as "links." Please note that Farmers State Bank is not associated with and has no control over the content or information on such links and, therefore, is not responsible for any such links or external websites. The links have been provided for your convenience. The content or information is such links is the sole responsibility of their authors and/or owners. Farmers State Bank is only offering these links as a service.