Recognition of a Customer’s Expectations of Privacy:
We recognize our customers’ right to privacy at The Olpe State Bank, and we recognize that customers have a right to expect their personal financial information to remain private and secure. We will maintain standards to ensure that this information is private and secure at all times.
Customer Benefits of Institution’s Information Management Practices:
We collect, retain, and use information about our customers only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to them. We collect and retain information about our customers only for specific business purposes, and we will tell them why we are collecting and retaining it upon request. We use information to protect and administer customer records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand the financial needs of The Olpe State Bank customers so that we can provide quality products and superior service.
Maintenance of Accurate Information:
We continually strive to maintain complete and accurate information about our customers and their accounts. If a customer believes that our records contain inaccurate or incomplete information we will investigate their concerns and correct any inaccuracies.
Limitations on Employee Access to Information:
Each Olpe State Bank employee is required to follow The Olpe State Bank’s Code of Conduct, which states that all customer information is considered private and privileged and is to be used solely for the purpose of providing The Olpe State Bank customers with the finest service available.
Protection of Information via Established Security Procedures:
We will safeguard information according to established security standards and procedures, and we will continually assess new technology for protecting information. Our employees are trained to understand and comply with these information principles.
Restrictions on the Disclosure of Account Information:
It is The Olpe State Bank’s policy not to reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties for their independent use, except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence or business matter, unless 1) the information is provided to help a customer initiated transaction; 2) the customer requests or permits it; 3) the disclosure is required by or allowed by law (e.g. subpoena, investigation of fraudulent activity, request by regulator, etc.); or 4) the customer has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and given the opportunity to decline(i.e., “opt out”).
Maintaining Customer Privacy in Business Relationships with Third Parties:
When The Olpe State Bank conducts business with third parties, it requires its vendors and suppliers to maintain similar standards of conduct regarding the privacy of personally identifiable customer information provided to them.
Providing Privacy Information to customers and Responding to Inquiries:
At The Olpe State Bank, we value our customer relationships. We want them to understand how we use the information provided by them and our commitment to ensuring their personal privacy.
ACCURACY AND INTEGRITY OF CONSUMER INFORMATION FURNISHED TO A CONSUMER REPORTING AGENCY
Olpe State Bank intends to comply with guidelines adopted by the Federal banking agencies for use when furnishing information to a Consumer Reporting Agency (CRA) regarding the accuracy and integrity of the information relating to consumers that such entities furnish to CRAs.
Responsibility of Furnishers of Credit Information
The Federal banking agencies are required to:
- Establish and maintain guidelines for use by each person that furnishes information to a CRA regarding the accuracy and integrity of the information relating to consumers that such entities furnish to CRAs, and update such guidelines as often as necessary; and
- Prescribe regulations requiring each person that furnishes information to a CRA to establish reasonable policies and procedures for implementing the established guidelines.
It is a prohibited practice for a person to furnish information relating to a consumer to any CRA if the person:
- Knows or has reasonable cause to believe that the information is inaccurate; or
- Has been notified by the consumer, at the address specified by the person for such notices, that specific information is inaccurate, and the information is, in fact, inaccurate.
Reasonable cause to believe that the information is inaccurate means: having specific knowledge, other than solely allegations by the consumer, which would cause a reasonable person to have substantial doubts about the accuracy of the information.
Olpe State Bank has procedures regarding the accuracy and integrity of consumer information that it furnishes to a consumer reporting agency. The bank reports all consumer loans except for single payment loans. This information is taken directly from our core system. Disputing Information Directly with the Furnisher
A consumer can dispute the accuracy of credit information either through a CRA or directly with the furnisher at the address specified for such notices.
A consumer who seeks to dispute directly with the Olpe State Bank shall provide a dispute notice (Attachment I) to the bank. That dispute notice should:
- Be in writing;
- Identify the specific information that is being disputed;
- Explain the basis for the dispute; and
- Include all supporting documentation required by the furnisher to substantiate the basis of the dispute
The bank within five days will:
- Conduct an investigation with respect to the disputed information;
- Review all relevant information provided by the consumer with the notice;
- Complete the investigation of the dispute and report the results of the investigation to the consumer before the end of a 30 day period that begins upon receipt of the notice; and
- If the investigation finds that the information reported was inaccurate promptly notify each CRA to which the bank furnished the inaccurate information and provide the CRA any correction that is necessary to make the information accurate.
The bank is not required to follow the above steps if it is determined that the dispute is frivolous or irrelevant, including:
- When the consumer fails to provide sufficient information to investigate the disputed information; or
- The dispute is substantially the same as a dispute previously submitted
No later than five business days after making a determination that a dispute is frivolous or irrelevant, the bank will provide a notice to the consumer by mail including:
- The reasons for the determination; and
- Identification of any information required to investigate the disputed information
This policy is a portion of the Gramm-Leach-Bliley Act of 1999.