Privacy Policy

The privacy rule governs when and how banks may share nonpublic personal information about consumers with nonaffiliated third parties.

All banks must develop initial and annual privacy notices.  The notices must describe in general terms the bank’s information sharing practices with an opt out notice, and a reasonable period of time for the consumer to opt out.  Banks that share nonpublic personal information about consumers with nonaffiliated third parties (outside of opt out exceptions delineated in the privacy rule) must also provide consumers with:

• An opt out notice
• A reasonable period of time for the consumer to opt out.

Peoples Bank does not share nonpublic information about consumers with nonaffiliated third parties, except to process and service a consumer’s transaction and to facilitate other normal business transactions.  This information sharing is the “Exception to opt out”.  Therefore, we are not required to give customers an opt out notice.

The initial notice is given at account opening.  Annual notices are mailed in April each year to all customers as long as required.

Exceptions to opt out:  A consumer cannot opt out of all information sharing.  First, the privacy rule does not govern information sharing among affiliated parties.  Second, the rule contains exceptions to allow transfers of nonpublic personal information to unaffiliated parties to process and service a consumer’s transaction, and to facilitate other normal business transactions.  For example, consumers cannot opt out when nonpublic personal information is shared with a nonaffiliated third party to:

• Market the bank’s own financial products or services
• Market financial products or services offered by the banks and another financial institution
• Process and service transactions the consumer requests or authorizes
• Protect against potential fraud or unauthorized transactions
• Respond to judicial process
• Comply with federal, state, or local requirements

 

Peoples Bank does not share nonpublic personal information with nonaffiliated third parties, except to process and service a consumer’s transaction and to facilitate other normal business transactions that are listed in the exceptions to opt out above.

If at any time, management makes a decision to share information in a manner that does not fall under the exceptions, the compliance officer will be notified in a sufficient amount of time to allow for changes to be made to our privacy notices, customers to be informed and given the right to opt out, and employees trained.

Prohibition on sharing account numbers:  The privacy rule prohibits a bank from disclosing an account number or access code for credit card, deposit, or transaction accounts to any nonaffiliated third party for use in marketing.  The rule contains two narrow exceptions to this general prohibition.  A bank may share account numbers in conjunction with marketing its own products as long as the service provider is not authorized to directly initiate charges to the accounts. 

Limits on reuse and redisclosure:  The privacy rule limits reuse and redisclosure of nonpublic personal information received from a nonaffiliated financial institution or disclosed to a nonaffiliated third party.  The specific limitations depend on whether the information was received pursuant to or outside of the notice and opt out exceptions.

State Law:  A provision under a State law that provides greater consumer protection than provided under the GLBA privacy provisions will supersede the Federal privacy rule.  The bank will be obligated to comply with the provisions of that State law to the extent those provisions provide greater consumer protection that the Federal privacy rules.  The Federal Trade Commission determines whether a particular State law provides greater protection.

Peoples Bank does not disclose account numbers or access codes to customer’s accounts except as permitted by law.  In the future, we will only do so to market our own products and the service will never be authorized to directly initiate charges to our customer’s accounts.

Peoples Bank schedule for providing notices will be as follows:

Initial Privacy Notices

• Existing Customers

 These will be mailed during the month of April.  We ordered our notices from Bankers Systems.

• All new bank customers after April 1, 2001 when the relationship is established.

 For joint accounts, Peoples Bank will only give one notice.  If the joint applicant requests a privacy notice, we will give them a notice at that time.

• Consumers who are not customers

 We are only required to give consumers who are not customers a disclosure if we intend to share nonpublic personal information about them.  We do not intend to share this information, therefore no notice is required.

• Revised Privacy Notice

 If management makes a decision to share nonpublic personal information in a manner not described in our most recent notice delivered to our customers and/or consumers, we will revise our notice, send a new notice, and give our customers the right to opt out if applicable.

Peoples Bank does not share nonpublic personal information about our customers or consumers outside the exceptions and do not at this time give customers the right to opt out.  If at any time we do share nonpublic personal information, we will provide consumers with at least 30 days to respond to an opt out notice that will be mailed.  If a consumer decides to opt out at a later date, we will comply with their request within 30 days.  We will comply with opt out directions until they are revoked in writing by the consumer. 

All of our notices will be in writing.

Service Providers:  Any contract that People Bank enters into after July 2, 2001 will require the service provider to maintain the confidentiality of nonpublic information, and the fact shall be so stated within the contract.  A list of service providers will be maintained by the Operations Officer and any service contract entered into will be forwarded to the Compliance Officer for review before such contract is signed.

Training:  All employees will be provided training on Privacy on an annual basis.  All employees have been trained prior to July 1, 2001 at Staff Meetings.

Vendors used in bank:

• Peoples bank has received a Privacy Policy for each vendor used, such as Clarke American, ChexSystems, and BSC which states that the vendor does not share private information unless it is:

Required by law
Specifically allowed by law or
Requested by the customer, directly or indirectly