CPM FCU PRIVACY POLICY

CPM FCU is committed to providing members with competitive products and services to meet their financial needs. Doing so necessitates that we share information about members to complete their transactions and to provide them with certain financial opportunities. CPM Federal collects only relevant information about our members that the law allows or requires us to have to conduct our business.

In the course of your work at the Credit Union you will have access to certain information that must always remain confidential and private. It is the responsibility of every employee to respect the confidentiality and privacy of such member information. All employees are required to respect and maintain member privacy, and those who violate this policy will be subject to immediate dismissal of employment.

SCOPE

This policy applies to all employees and volunteers with access to member information.

TRAINING

The training department is responsible for initial and ongoing training of credit union personnel of the requirements of the Privacy Policy.

INFORMATION WE COLLECT

CPM Federal collects nonpublic information about members from the following sources:

• Information we receive from membership and loan applications.
• Information about member transactions with us or others.
• Information we receive from consumer reporting agencies.
• Information obtained when verifying the information members provide on an application or other forms, such as current or past employers, other institutions where members conduct financial transactions, etc.

INFORMATION WE MAY DISCLOSE

CPM Federal may disclose the following nonpublic information about members:

• Information we receive on applications and other forms, such as a member’s name, address, social security number, and income.
• Information we receive from a consumer-reporting agency, such as creditworthiness and credit history.
• Information about transactions with us or other companies that work closely with us to provide members with financial products and services, such as account balances, payment history and credit card usage.

HOW WE PROTECT MEMBER INFORMATION

We restrict access to nonpublic personal information and maintain physical, electronic and procedural safeguards that comply with federal regulations to guard against intrusion of member’s nonpublic personal information.
We also suggest member’s safeguard their financial information to prevent identity theft, unauthorized intrusion, etc. by adhering to the information below,

• Ensure members know to protect account numbers, PIN’s (personal identification numbers), social security #’s and passwords to prevent unauthorized account access. Should members receive such a request or message to contact someone outside of CPM FCU with their account #, PIN #, etc., they are to notify us directly to safeguard against fraudulent activity on their account(s).
•  Ensure members know to keep their contact information current, including mobile phone and e-mail information. If we detect potentially fraudulent on their account, we must have current information on file to ensure we can contact them immediately.
• Ensure members know to contact us if they think their confidential information has been compromised.

DISCLOSURE ABOUT FORMER MEMBERS

If a member terminates his or her membership with CPM Federal, employees shall not share information that the Credit Union has collected about that member, except as permitted or required by law.

REQUIRED DISCLOSURES (Exhibit 1)

Privacy disclosures must be given to all members. Below are instances when disclosures must be given:

•  New accounts- the Credit Union must provide disclosures for new member relationships not later than when the person becomes a member of the Credit Union. This disclosure will be given at the same time the TIS new account disclosure is given.
• Annual disclosures- the Credit Union must provide privacy notices annually.

TERMINATION OF ANNUAL PRIVACY NOTICES

The Credit Union can stop providing annual notices only:

•  When a person is no longer a member.
•  When a member has requested that no member information be mailed (such as a “no-mail” flag on the account) as long as the privacy notice is available to the member on request.

HOW NOTICES MUST BE GIVEN

The privacy notice must be “clear and conspicuous” which means that the notice must be reasonably understandable and designed to call attention to the nature and significance of the information in the notice. CPM Federal can include the notice with other information, such as including it as part of the Credit Union’s newsletter, if the notice uses distinctive type size, style and graphics. The notice must be delivered in written or electronic formats and the member must be able to retain the notice.

INTERNET DISCLOSURES

For the member’s protection, CPM Federal uses firewalls to secure online banking sessions. These firewalls safeguard banking sessions from intruders.

Generally our e-mails are not secure. Accordingly, employees are prohibited from transmitting account numbers or other private or confidential member or Credit Union information via e-mail.

When members log on to our CU Anytime banking program, we use a “cookie” as part of our interaction with members’ internet browser. A “cookie” is a small text file or text identifier placed on member computers by CPM Federal. Cookies are commonly used and do not harm members’ systems.

CPM Federal does not knowingly collect or share any information from minors (those under the age of 18) who may access CPM Federal’s website.