Greater Watertown Federal Credit Union Privacy Policy

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Greater Watertown Federal Credit Union is committed to providing members with financial products and services to meet their needs and to reach their financial goals. We are equally committed to protecting members’ privacy. The following constitutes GWFCU policy on protecting the privacy of members’ nonpublic personal information.

The Credit Union collects nonpublic personal information about members from the following sources:

• Information we receive from you on applications and other forms;
• Information about your transactions with us or others including those companies that work closely with us to provide you with diverse financial products and services;
• Information we receive from credit reporting agency; and
• Information obtained when verifying the information you provide on an application or other forms(s) (this may be obtained from your current or past employers, or from other institutions where you conduct financial transactions).

We may disclose all of the information we collect, as described above, to companies that perform marketing or other services on our behalf or to other financial institutions with whom we have joint marketing agreements. To protect our members’ nonpublic personal information, we will only use vendors that agree that they will maintain the strictest confidentiality of members’ nonpublic information and only use the information for the purposes intended. We will not allow these companies to sell any nonpublic personal member information to other third parties.

In order to conduct the business operations of the Credit Union, we may also disclose nonpublic personal information about members under other circumstances as permitted or required by law. These disclosures typically include information to process transactions on our behalf, to conduct the operation of the Credit Union, to follow members’ authorized instructions, or to protect the security of our financial records.

Restriction on Sharing Account Numbers

Greater Watertown Federal Credit Union prohibits the sharing of account numbers with any nonaffiliated third party for use in telemarketing, direct mail marketing or marketing through electronic mail to members.

Disclosure of Information About Former Members

Greater Watertown Federal Credit Union will not share nonpublic personal information that has been collected about a member once that member has terminated their membership with the Credit Union except as may be permitted by law.

How We Protect Member Information

Greater Watertown Federal Credit Union restricts access to nonpublic personal information about members to those employees who need to know that information to provide products and services to those members. It is required that all officers, directors, members of committees and employees of this credit union hold in confidence all transactions of this credit union with its members and all information respecting their personal affairs, except when permitted by state or federal law. The credit union also maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard the nonpublic personal information of members.

Distribution of Policy

Greater Watertown Federal Credit Union’s privacy policy will be distributed in three manners:

• As an initial privacy disclosure. All existing members and joint account owners (one notice will service for both) will receive this policy in the mail prior to July 1, 2001 as required by law. Nonmember co-borrowers and guarantors will also receive the notice if the credit union shares their nonpublic personal information with nonaffiliated third parties. Nonmembers who use credit union services (i.e. foreign ATM users) will receive the notice if the credit union shares nonpublic personal information with nonaffiliated third parties. The privacy disclosure will be written in a clear, conspicuous and retainable manner.
• New member after July 1, 2001. New members will be given a privacy notice when opening their membership account. New nonmembers whose loan servicing rights are purchased by the credit union will also receive disclosure. The privacy disclosure will be written in a clear, conspicuous and retainable manner.
• Annual notice. All existing members, joint account owners (one notice will service for both), and nonmembers whose loan serving rights are purchased by the credit union will receive this policy in the mail on an annual basis after receiving the initial privacy disclosure. Nonmember co-borrowers and guarantors will also receive an annual notice if the credit union shares their nonpublic personal information with nonaffiliated third parties. The privacy disclosure will be written in a clear, conspicuous and retainable manner.

Opt Out Requirement

Currently, the credit union does not disclose any nonpublic personal information to nonaffiliated third parties that would require the credit union to provide members with an option to opt out of information disclosure. The credit union has evaluated all nonpublic information that is disclosed; and at this time all disclosures fit into one of the following exceptions to the opt out option Requirement:

1. Affiliates (CUSOs)
2. Nonaffiliated third parties that process or service transactions.
3. Joint Marketing agreements with other financial institutions. (Signed contract needed)
4. Nonaffiliated third party service providers. (Signed contract needed)
5. Laundry list exceptions

If it becomes necessary to provide an option to opt out it will be added to the credit union’s privacy policy and disclosed to members as described above.