Privacy Policy.
overview
BankProv is a full-service commercially focused bank providing a broad range of products and services to its customers. At BankProv, protecting our customers’ privacy and financial assets has always been at the core of our business. We value the trust that our customers have placed in BankProv by choosing to do business with us. The Bank recognizes its responsibility to keep the information that we obtain about our customers secure and confidential in accordance with this Privacy Policy. BankProv may share customer or former customer non-public personal information with outside companies as allowed by applicable state and federal laws and regulations (collectively, “Applicable Law”) or as specifically authorized by the customer, and consistent with BankProv’s disclosures to the customer in all applicable privacy notices.
purpose
The Board of Directors has adopted this policy in order to comply with Applicable Law. The Board of Directors and management recognize and respect the privacy expectations of its customers and consider the safekeeping of customer information a fundamental responsibility of the Bank.
scope
Information Collected
In order to deliver products and services to our customers as effectively and conveniently as possible and to better understand the financial needs of our customers, BankProv collects, retains, and uses various types of information about our customers. This includes demographic information, such as name, address, phone number or social security number, and credit information which can include information related to accounts with us or others. This information comes either directly from the customer (for example, from applications prepared by the customer, financial statements that the customer provides to us, e-mails sent to us, or from transactions on customer accounts with us) or from outside sources, such as credit reporting agencies and public records. If the customer should visit our internet website, we do not necessarily collect identifying information, but we may use standard software (called “cookies”) to collect non-identifying information about the internet usage, such as the date and time our site was accessed, and the web browser that was used by the customer. Customers may submit identifying information to the Bank by utilizing one of our web forms to express interest in a product or service.
requirements
Information Protection and Accuracy
BankProv diligently maintains physical, electronic, and procedural safeguards that comply with applicable federal standards to guard private personal information and to assist us in preventing unauthorized access to that information. The only employees or companies who can access personal customer information are those who use it to service a customer’s account, to respond to customers’ questions, or those who require access to provide operational support for banking services. We will ensure that our employees understand the importance of maintaining the confidentiality of customer information and that they fully understand the Bank’s Privacy Policy through ongoing training. We also make every effort to ensure that the consumer and personal information that we maintain about our customers is accurate, up-to-date, and complete.
Sharing Information with Outside Third Parties
BankProv may employ outside marketing companies on a contract basis to assist us in marketing our products and services to our customers. Information that we may share with our marketing partners includes name, address, and telephone number, as well as, a general description of the type of relationships maintained with us (for example, we may indicate that a customer has a deposit account or a mortgage with us). We may disclose account numbers, social security numbers, or any credit or transaction information to our marketing partners pursuant to our agreements, so long as consistent with Applicable Law.
We will maintain written contracts with all of our partners which will require them to treat customer personal information in a confidential manner to comply with Applicable Law.
BankProv may share information about our customers with other companies to allow the Bank to conduct our business, comply with Applicable Law, protect against fraud, or as authorized by our customers. We may also provide information to regulatory authorities, consumer reporting agencies and law enforcement agencies in accordance with Applicable Law. Vendors or service companies that we retain to process information about our customers are required to conform to our privacy standards. The Bank may sell or exchange customer information pursuant to any agreements between the Bank and the outside company, as long as doing so is consistent with the requirements of Applicable Law.
Privacy Notices Provided by the Bank
It is the policy of the Bank to follow Regulation P for the issuance of its initial, revised, and annual privacy notices. The Bank will also provide any state specific privacy notices, in the event that the notice provided under Regulation P does not meet all of the requirements of Applicable Law.
responsibility and oversight
Board of Directors
The Board of Directors is the source of all authority and responsibility. While responsible for the oversight of BankProv’s Privacy Policy, the Board delegate the day-to-day management of the
Privacy Policy and its processes to Bank management. The Board is responsible for the annual review and approval of the Privacy Policy.
Compliance Department
The Compliance Department is responsible for the update and any necessary distribution of the Bank’s Privacy Notices. The Compliance Department assigns appropriate privacy training to employees based on their job function and role.
Information Security Department
The Information Security Department manages the Information Security Standards that are required by the Gramm-Leach-Bliley Act (GLBA). Information on the controls and processes relating to the Information Security Program can be found in the Information Technology and Security Management Program.
Business Units
Customer-facing business units are responsible for providing to the Bank’s customers the appropriate state and/or federal Privacy Notices when an account is opened.
references
Information Technology and Security Management Program
Privacy Notice
Privacy Notice Mailing Procedures
administration
This policy will be administered by the Bank’s Compliance Officer, and submitted to the Board for approval on an annual basis. The document shall be stored in the Bank’s intranet. It is suitable for sharing with all employees.
Approved by: BankProv Board of Directors