PRIVACY POLICY
GraCo
Federal Credit Union will fully comply with the provisions of both
the Gramm-Leach-Bliley Act and the NCUA Privacy Regulations. In
doing so, GraCo Federal Credit Union has prepared a privacy
policy, will provide privacy disclosures, and, where required,
give members the
opportunity to opt-out of certain disclosures.
Information collected
and how it is used:
Information Collected -GraCo FCU will collect information
necessary to provide our members products and services, or as
required by law. GraCo FCU collects information about members and
their account(s) from the following sources:
- from member
applications (loans, accounts, services, etc.) or other forms;
- member transaction(s)
with the credit union, our affiliates, or others; and/or
- information we receive
from a consumer reporting agency.
Former Member Information
GraCo FCU will not share information about members who have
terminated their relationship with the credit union, unless
permitted or required by law to do so.
Annual privacy notices will no longer be sent to those who have
terminated their relationship with GraCo FCU.
Information Disclosed to
Third Parties Member information is not shared with
non-affiliated third parties. GraCo FCU does not share member information with non-affiliated
third parties unless authorized or permitted by law. If GraCo FCU
shares information in the future that requires an opt -out form
to be sent to members, one will be provided.
GraCo FCU reserves the
right to share confidential member information with attorneys,
accountants, auditors, consumer reporting agencies, and, to the
extent permitted by the law, to law enforcement agencies and other
official bodies without triggering a right for members to receive
an opt -out form.
Contracts with
affiliates Under both the Gramm-Leach-Bliley Act and NCUA Privacy
regulations, GraCo FCU may share member information with
affiliates of GraCo FCU. The term "affiliate" means
"any company that controls, is controlled by, or is under
common control with another company. However, GraCo FCU has
provided in its contracts with these affiliates that member
information will be kept confidential.
Fair Credit Reporting Act
GraCo FCU reserves the right to share information about the
creditworthiness related to GraCo FCU's transactions or
experiences with members without triggering a right for such
members to receive a disclosure and an opt-out form.
Safeguarding Member
Information
Credit Union Security -GraCo FCU will maintain security
measures consistent with the requirements of federal and state
regulations, including risk management systems designed to prevent
unauthorized access, both internal and external, to member
information.
GraCo FCU has procedures
in place to protect member information systems in the event of a
natural disaster, intentional destruction, or technical
failure.
GraCo FCU regularly tests
the efficacy of its member information systems to ensure proper
working order. These tests may be conducted by independent third
parties or staff independent of those that have developed or
maintained our security programs.
GraCo FCU restricts
access to areas that contain member information.
Credit Union Employees
and Officials -GraCo FCU employees with access to member
information will receive a copy of GraCo FCU's privacy policy, and
will be notified of the importance of maintaining the
confidentiality of member information.
GraCo FCU has established
procedures to eliminate internal and external unauthorized access
to member information.
GraCo FCU's employees
will be informed of and will have access to information regarding
the proper procedures for filing reports to the appropriate
regulatory and law enforcement agencies. GraCo FCU may conduct
background checks on its employees to ensure compliance with our
security program. GraCo FCU thoroughly investigates any
allegations of employee misconduct.
GraCo FCU limits access
to sensitive information to specific employees to ensure
confidentiality of member information.
Individuals other than
credit union employees, including board members and
volunteers, may have limited access to member information. GraCo
FCU has established confidentiality controls in order to protect
improper access to, and distribution of, member information.
Third Party Vendors
GraCo FCU has contracted with service providers to install
and/or maintain our member information system, to process our Visa
credit and debit cards, to process our A TM transactions, and to
track the insurance policies required for collateralized loans.
GraCo FCU has exercised due diligence in selecting our
service providers to ensure that proper security measures are in
place to protect member information. GraCo FCU may regularly
monitor service providers to ensure that they continue to satisfy
their obligations.
Protection of Member
Account Numbers
GraCo FCU will only share account numbers or access codes as
authorized or required by law.
Joint Marketing
Agreements
GraCo FCU may enter into joint marketing agreements to provide
member information to non-affiliated third parties to perform
services for the credit union or functions on behalf of the credit
union.
GraCo FCU includes
language in these joint marketing agreements prohibiting
non-affiliated third parties from using or disclosing member
information for purposes other than in the ordinary course of
business to carry out the purposes for which the information was
provided. Contact GraCo FCU with questions at 989-463-1247 or Toll
Free at 866-463-1247 or visit our office located at 305 W. Downie
in Alma.