National Bankers
Association
Privacy Principles
1. Recognition of a
Customer's Expectation of Privacy
Financial institutions
should recognize and respect the privacy expectations of their customers and
explain principles of financial privacy to their customers in an appropriate
fashion. This could be accomplished by making available privacy guidelines
and/or providing a series of questions and answers about financial privacy to
those customers.
2. Use, Collection and
Retention of Customer Information Only if the Institution Believes the Customer
Will Benefit
Financial institutions should collect and use information about individual
customers only where the institution reasonably believes it would be useful
(and allowed by law) to administering that organization's business and to
provide products, services and other opportunities to their customers.
3. Maintenance of
Accurate Information
Financial institutions should establish procedures so that a customer's
financial information is as accurate, current and complete as possible.
Financial institutions should also respond to requests to correct inaccurate
information as expeditiously as possible.
4. Limiting Employee
Access to Information
Financial institutions should craft policies and procedures that limit employee
access to personally identifiable information to those with a business reason
for knowing such information. Financial institutions should create training
programs so that employees will understand the importance of confidentiality
and customer privacy. Financial institutions should also establish compliance
procedures for such privacy responsibilities and create a mechanism for
enforcement.
5. Protection of
Information via Established Security Procedures
Financial institutions should maintain appropriate security standards and
procedures regarding unauthorized access to customer information.
6. Restrictions on the
Disclosure of Account Information
Financial institutions should not reveal specific information about customer
accounts or other personally identifiable data to unaffiliated third parties,
unless 1) the information is provided to help complete a customer initiated
transaction; 2) the customer requests it; 3) the disclosure is required by/or
allowed by law (i.e. investigation of fraudulent activity); or 4) the customer
has been informed about the possibility of such disclosure through a prior
communication and is given the opportunity to decline (i.e. "opt
out").
7. Maintaining Customer
Privacy in Business Relationships With Third Parties
If personably identifiable customer information is provided to a third party,
the financial institutions should require the third party to adhere to similar
privacy principles that provide for keeping such information confidential.
8. An Institution's Privacy Principles or Policies Will Be Made Known to
the Customer
Financial institutions should devise methods of providing a customer with an
understanding of their privacy policies. Customers that are concerned about
financial privacy will want to know about an institution's treatment of this
important issue. Some institutions may include their privacy principles in an
employee code of conduct manual or some other similar document while others may
have a separate document. However, each financial institution should create a
method for providing to the public its privacy policies.
Questions? Please contact the webmaster@nationalbankers.org
for more information.
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