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THE COMMUNITY NATIONAL BANK
PERSONAL ELECTRONIC BANKING PRIVACY
POLICY &
The Community National Bank understands and deeply appreciates the trust and confidence of all of the customers who have made us their bank of choice. In order to protect this special trust and confidence, it is Bank policy that both the financial records of customers and all relationships between customers and the Bank are to be considered highly confidential. Customer financial information or records will not be disclosed to any individual or organization outside the Bank without the express approval of the President under the following mandate
OBJECTIVES AND GOALS The objective of this policy is to establish internal standards to ensure the protection of all customer information and banking relationships; particularly disclosure of such information to sources outside of the Bank. The specific goals of this policy are to maintain total confidentiality of customer information, minimize the risk inherent in improper disclosure of information, and minimize fraud and financial loss.
EXCEPTIONS TO POLICY Personal information of our customers may be supplied to a third party under the following conditions:
REQUIREMENTS The following requirements pertain to all requests for customer information or records.
COLLECTION AND USE OF PERSONAL INFORMATION The Community National Bank collects and retains customer information when it is necessary for business purposes. This information is used to administer customers' funds, accounts, and records, to understand customers' banking needs, to improve bank products and services, and to comply with applicable federal and state laws and regulations.
MAINTENANCE OF ACCURATE INFORMATION The Bank makes every effort to ensure that all customer information compiled by the Bank is as accurate, current and complete as possible. In the event a customer disputes the accuracy or completeness of the Bank's information, we will conduct a complete investigation and report the results to the customer as soon as possible. Customer complaints regarding their personal information should be sent to: The Community National Bank The Community National Bank does not recommend sending detailed account information or other personal information via internet e-mail due to potential security concerns.
BANK STAFF ACCESS TO PERSONAL INFORMATION Personal customer information is restricted to those individuals within the Bank that have a legitimate business reason to review such information. In addition, all Bank employees are educated regarding the importance of confidentiality of customer information and customer relationships. To further safeguard the confidentiality of customers' personal information, specific user names and passwords must be used by approved Bank employees to access any on-line customer records or information.
THIRD PARTY RELATIONSHIPS The Community National Bank recognizes that the use of third party vendors to provide certain products and services to our customers is a necessary adjunct of the banking business. Selection of a vendor or service provider to process any type of customer information or records requires prudent judgment and appropriate due diligence prior to any data being furnished to the vendor. Service providers and vendors must agree that all such information will be properly used for the purposes intended and provide data security commensurate with that furnished for in-house information.
INFORMATION SECURITY Please see the Information Security page following.
PERSONAL INFORMATION DISPOSAL The Community National Bank retains customer information according to legal and regulatory requirements in secure facilities within the Bank. When customer information is no longer needed or becomes outdated or obsolete, electronic information is destroyed by deletion from computer systems and any related magnetic storage media are erased. Paper based records are destroyed by shredding or pulverization.
ONLINE BANKING SECURITY Personal electronic banking systems require effective and reliable security measures to ensure customer privacy, maintain data integrity, and protect computer and telecommunications systems from unauthorized intrusions, misuse and fraud. The Community National Bank's Information Security Program addresses network and data access, user authentication, transaction verification, and virus protection. Network and data access controls provide for verification and enforcement of a customer's authorized right to access a bank network, application, and data. These controls prevent unauthorized individuals from entering critical facilities, retrieving confidential information, or allowing access to bank software and operating systems. User authentication determines whether the user of the system is whom they claim to be. This process requires that the identity of the electronic banking customer be authenticated when they access their personal account information or when they engage in on-line transactions for bank products or services. The Community National Bank utilizes passwords, firewalls, and encryption to create a secure and confidential electronic banking environment for our customers. Transaction verification procedures ensure valid and authentic electronic communications between The Community National Bank and our customers. Specific audit trails of all parties who initiate transactions are established, verified and maintained. Virus protection is an extremely important security control since any connection made to an external or internal network is an opportunity for infection by a computer virus. The Community National Bank utilizes an effective bank-wide detection and prevention program to reduce the likelihood of computer virus infection.
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