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 Privacy
Notice Disclosure to Members 12 CFR § 716
The directors, management, and staff of Berks Community Federal Credit
Union are concerned about and respect the privacy of our members'
personal financial information. We understand that our members furnish
sensitive information to the credit union in the course of daily
business, and the credit union is committed to treating such information
responsibly. We know that our members expect privacy and security for
their personal and financial affairs.
The credit union will take all the necessary steps to safeguard
sensitive information that has been entrusted to us by our members. The
following information outlines this credit union's practices regarding
personally identifiable financial information for members and others
with whom we establish a "member relationship" pursuant to 12 CFR §716
of the National Credit Union Administration's Rules and Regulations.
TYPES OF INFORMATION THE CREDIT UNION COLLECTS
At Berks Community Federal Credit Union, we collect nonpublic personal
information from many sources. The credit union collects nonpublic
personal information directly from members, joint owners, co-borrowers,
and guarantors on various applications and forms. For example, loan
applications, deposit account applications, and requests for information
about accounts or products and services.
The credit union also collects information as a result of transactions
between the credit union and such individuals, and as a result of
providing our products and services. This includes transaction
information from share drafts (checks), debit cards, credit cards,
automated teller machine (ATM) cards, and electronic transfers (for
example, home banking or automated clearinghouse (ACH) transactions).
Nonpublic personal information does not include information the credit
union obtains from government records, widely distributed media, or
government mandated disclosures.
TYPES OF INFORMATION THE CREDIT UNION DISCLOSES
The Berks Community Federal Credit Union may disclose the following
types of information about current or former members to our affiliates:
- Identification information, such as name, address and telephone
number;
- Transactional Information, and;
- Deposit or loan account experience.
Example of the types of businesses we are affiliated with are listed
below:
MICRODYNAMICS Distribution mail center for monthly and quarterly
1400 Shore Road statements
Naperville, Il 60563
RTC Local Mail Distribution Center for mass marketing
56 Seip Lane mailings
Shoemakersville, PA 19555
Precision Forms & Graphics Distribution Center that prints and mails
notices
258 Wilmington Pike for Enterprise Car Sales
Chadds Ford, PA 19317
Peripheral Systems, Inc. Microfilm
Bertolet Mill Road
Oley, PA 19547
Safeguarding Member Information
At Berks Community Federal Credit Union we protect member privacy by
ensuring that only employees who have a business reason for knowing
information have access to it. The credit union has appointed a
Financial Privacy Coordinator Team, who is responsible for maintaining
internal procedures to ensure that our members' information is
protected. For example, information in loan files can only be accessed
by employees who work in the loan origination or loan operations
department.
All employees have a copy of this policy and the credit union's Member
Financial Records Privacy Policy and are trained at least annually
regarding the importance of safeguarding member information. The
Financial Privacy Coordinator Team and appropriate other staff members
will take disciplinary action against any employee who violates the
credit union's privacy policy and procedures.
If the policy or practice changes, for example, adding a category of
information that will be disclosed to a third party, the credit union
will notify existing members and give them an appropriate time period to
opt out of the disclosure.
Members' Right to Opt Out of Sharing Agreements
Members have the right to opt out of the credit union's sharing
agreements with certain affiliates and non-affiliates by completing the
"OPT OUT Form" and returning it to the credit union in an acceptable
manner described on the form.
If a member signs the opt-out notice at the time an account is opened or
application processed, the credit union will honor the request
immediately.
However, members may opt out of the information sharing agreements at
any time. If a member notifies the credit union after an account is
opened or application processed, the credit union agrees to stop sharing
the member's information within 30 days from the date the member's
request is received.
Exceptions to a Member's Opt-Out Rights
By law, Berks Community Federal Credit Union may share personal
information about members without allowing the opportunity to opt out in
the following circumstances:
With companies that perform credit card transaction processing for the credit union.
- If the transaction, service, or product is requested or
authorized by the member;
- To maintain or service a member's merchant account as part of a private
label credit card or other loan extension program;
- In connection with a securization, secondary market (including
service rights), or similar transaction related to a consumer.
For disclosures that are necessary to enforce the credit union's legal
or contractual rights or the rights of any other person who is engaged
in the financial transaction.
For disclosures required in the ordinary course of our business, such as
in the settlement of claims or benefits, the confirmation of information
to a member or their agent, and the billing, processing, or clearing of
items in the normal course of business.
To provide information to insurance rate advisory organizations,
guaranty funds or agencies,
agencies that are rating the credit union, persons that are assessing
the credit union within industry standards, and the credit union's
attorney, accountants, and auditors.
To the extent permissible under the Right to Financial Privacy Act (RFPA).
See the credit union's policies for guidance on compliance with the RFPA.
To a consumer reporting agency under the Fair Credit Reporting Act.
To comply with federal, state, or local laws, rules and other applicable
legal requirements. See the credit union's policies for guidance on
compliance with these exceptions.
Berks Community Federal Credit Union may also disclose personally
identifiable information to non-affiliated third parties we engage to
market our own services or products to members. The credit union will
not provide member's personal information to non-credit union companies
for the purpose of their independent telemarketing or direct mail
marketing of any non-financial products or services.
If the credit union shares information with a third party,
non-affiliated marketing firm for the purpose of telling our members
about our new products or services, the credit union will enter into a
written agreement with the third party that will require that party to
maintain confidentiality of the information in the same manner the
credit union would and restrict its use.
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