I. INTRODUCTION
At First National Bank of Oneida, service to our customers is our foremost priority. Part of that service necessarily entails the protection of our customers' personal and financial privacy concerning information which has been entrusted to us. We intend to do that in several ways, for example:
- by establishing security procedures and internal control systems through technology;
and - by training and making sure that our employees understand and are committed to the philosophy of confidentiality and safeguarding our customers' financial and personal privacy;
and also - by compliance with our obligations to preserve our customers' trust and confidence under the Right to Financial Privacy Act and the Fair Credit Reporting Act and the implementing regulations thereunder;
and lastly, - by continually reviewing new measures and upgraded security practices to take advantage of the latest technology for that purpose and as circumstances may develop by which changes in strategy or implementation are warranted.
To this end, the First National Bank has adopted this Privacy Policy. The following outline details the guidelines by which this policy is instituted.
II. DISCLOSURE OF CUSTOMER INFORMATION
First National Bank of Oneida will not share nor sell individual customer information to any unaffiliated third parties for marketing purposes.
Customer information will only be disclosed to authorized account holders, and then only after identification of those particular account holders have been verified. Verifying information may include social security number, date of birth, place of birth mother's maiden name, signature, and/or other identifying information. First National Bank may in its discretion, require that such request be made orally in person with written identification.
First National Bank employees will not share personal or financial customer information with unaffiliated third parties except when legally required to do so (in order to comply with federal or state laws/regulations, and governmental or court orders) or when legally permitted to serve the customer's interests (such as disclosure to reputable credit reporting agencies). Information will only be disclosed to third parties under the following conditions:
- Where necessary to complete a transaction initiated by the customer.
- Where necessary to comply with contractual obligations to additional parties in interest in an account or contractual relationship.
- In order to report the existence and condition of an account to companies such as reputable credit bureaus or merchants.
- In order to comply with qualified governmental or court orders and/or subpoenas.
- If we have the written or verified oral permission of the account holder.
First National Bank will provide certain customer information to unaffiliated third party companies that we hire to provide us operational support. These unaffiliated third party companies provide services that allow us to complete transactions - for example in the area of real estate loans. Examples of such services provided by third parties necessarily acquiring certain customer information in the area of real estate loans would include, but not necessarily be limited to, title companies, appraisers, and credit reporting agencies. Two other examples of a third parties providing us with operational support, which would necessarily be privy to certain customer information, would be the bank' s external auditors and the bank's federal regulators, who both are responsible for reviewing our bank operations for purposes of assisting us in maintaining the safety and soundness of our bank. As stated above, First National Bank will not knowingly do business with any unaffiliated third party provider or company that uses or sells customer information for marketing purposes.
III. COLLECTION, RETENTION AND USE OF INFORMATION
First National Bank may collect, retain and use personal information about customers (for example, we will obtain a credit reports for a loan requests), but only when we believe it is reasonably useful and necessary in the conduct of our business including the provision of products, services and other opportunities to our respective customers.
IV. MAINTENANCE OF ACCURATE INFORMATION
First National Bank will endeavor to maintain up to date account information and to correct any inaccurate information in a timely manner, as soon as we are made aware of such inaccuracies.
Inquiry concerning information maintained, may be directed to the Bank by the concerned customer by contacting the Bank at the address posted at the end of this Policy.
Corrections or additions to such information may be made by the concerned customer at the same address.
V. EMPLOYEE ACCESS TO INFORMATION AND ENFORCEMENT
All First National Bank employees are trained about the utmost importance of customer confidentiality and privacy. As a condition of their employment they are required to learn and follow this Privacy Policy. Those employees for whom customer account access and/or knowledge is not required in the performance of their jobs are not entitled to information concerning such customer accounts and information. Employees of First National Bank are instructed to access customer information on a strict need to know basis only.
Any employee that violates or otherwise breaches (even unintentionally) this Privacy Policy will be subject to disciplinary measures up to and including termination of service.
Copies of the foregoing First National Bank Privacy Policy are available upon request, by calling or writing to:
First National Bank of Oneida
Customer Service Department
P.O. Box 4699
Oneida, Tennessee 37841-4699
(423) 569-8586
www.fnboneida.com
ABOUT CHILDREN'S ONLINE PRIVACY
The Children's Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13. First National Bank's websites and online services are not directed to children under the age of 13, nor is information knowingly collected from them. For additional information on COPPA protections, link to the Federal Trade Commission's website at http://www.ftc.gov/privacy/privacyinitiatives/childrens. For further information, the Federal Government has created a Web site, Kidz Privacy, aimed at educating both parents and children about the dangers of the Internet and how to browse safely.
Equal Housing Lender • ©2007 First National Bank. All rights reserved.