<

THE COMMUNITY NATIONAL BANK

 

PERSONAL ELECTRONIC BANKING PRIVACY POLICY &
ONLINE BANKING SECURITY

 

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:

  1. The customer requests that their personal information be provided.
  2. The information is provided to complete a transaction initiated and properly authorized by the customer.
  3. The information is provided to a valid consumer credit reporting agency.
  4. The information is provided in cooperation with governmental agencies and the court systems in response to legitimate requests for customer information and records initiated according to the stipulations of the Right to Financial Privacy Act of 1978 (12 U.S.C. 3401) (Court Order, Search Warrant, Subpoena). 
  5. The information provided is required to be reported under federal law.
  6. The customer has been properly informed about the possibility of disclosure and provided with an opportunity to refuse such disclosure of their personal information.

 

REQUIREMENTS

The following requirements pertain to all requests for customer information or records.

  • No list of Bank customers will be given, sold or otherwise provided to any outside source for the purpose of marketing products or services not provided by the Bank.
  • The Bank will not respond to any informal request for access to the information contained in the financial records of any customer. Information about the Bank or its customers will only be disclosed in response to an appropriate formal subpoena process.
  • The Security Officer is responsible for receiving and processing all governmental and private litigation subpoenas served on the Bank. The Bank staff is instructed to refer federal agents, law enforcement personnel or other process servers to the Security Department.
  • If any officer or employee other than the Security Officer is served with a subpoena, the served employee will immediately deliver the subpoena to the Security Officer without disclosing its contents to other officers or employees.
  • Whenever the Bank or any member of the staff is served with a subpoena in a private lawsuit, appropriate legal counsel will be contacted to protect the Bank from liability.
  • All newly hired officers and employees will be made aware of the Bank's subpoena receipt requirements as part of their orientation.

 

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
    1400 East Second Street
    P.O. Box 577
    Franklin OH 45005
    (937) 746-1520

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.