PRIVACY POLICY

First National Bank of Walker (the "Bank") is implementing this privacy policy because a fundamental component of the bank/customer relationship is a customer´s trust in this institution and because we respect the expectations of our customers regarding privacy and confidentiality. Protecting your privacy, along with your financial assets, is at the core of our business. You have chosen to do business with us, and we recognize our obligation to limit access to the information you provide us.

This policy has been adopted by the Bank´s board of directors as of the 3/21/01 board meeting. Bank management reviewed a variety of issuances from federal banking agencies, as well as the U.S. Banking Industry Privacy Principles, and carefully considered the policy in light of the bank´s particular needs, including the bank´s size, bank´s involvement with third parties, and the needs of our customers.

COLLECTION AND USE OF INFORMATION

The Bank collects, retains and uses information about customers only when it is useful and lawful for our standard business purposes, when we believe it is allowed by law, reasonably useful in administering our business and providing products, services and other opportunities to our customers. Our "business" referred to in the preceding sentence includes opening and maintaining accounts or providing loans, investment accounts, insurance coverage or providing additional financial products or services advising you of new products or services.

MAINTENANCE OF ACCURATE INFORMATION

Keeping your account information accurate and up to date is very important. If you ever find that your account information is incomplete, inaccurate or not current, please call (218-547-1160) or write us at: First National Bank of Walker, PO Box 520, Walker, MN 56484 or any of our branch locations. We will correct any erroneous information.

EMPLOYEE ACCESS TO INFORMATION AND ENFORCEMENT

Bank limits employee access to customer personal information to only those bank administrators with a business reason for knowing such information. Bank also educates all employees about the importance of confidentiality and customer privacy. All Bank employees are required to sign a confidentiality statement when they are hired. In addition, to insure that employees understand the importance of this issue to our customer, the bank also conducts annual training sessions regarding privacy and confidentiality.

SAFEGUARDING THE SECURITY OF CUSTOMER INFORMATION

The Bank maintains physical, electronic and procedural safeguards that comply with federal standards and regulations to guard your information.

RESTRICTION ON DISCLOSURES OF ACCOUNT INFORMATION

The Bank will disclose information to third parties about your credit, your accounts, and your transactions under any one of the following conditions:
  1. When it is necessary for completing a transaction initiated by you.
  2. To verify the existence and conditions of the account or loan for reputable information reporting agencies.
  3. In order to comply with a government agency directive, court order, or regulatory examination.
  4. When you give the bank permission.
  5. When it is consistent with your agreement or contract with the Bank.
  6. In order to protect you, your interests, the interests of the Bank, or if we suspect fraud or illegal activity.

MAINTAINING CUSTOMER PRIVACY IN BUSINESS RELATIONSHIPS WITH THIRD PARTIES

The Bank follows strict privacy procedures in regard to customer information and will take the necessary steps to ensure protection of customer information. Except as otherwise stated in this policy, the Bank will not sell or share customer information with third parties. In some cases it may be necessary to share information with third party business partners. This may be necessary to provide you with requested products or services. The Bank requires all third parties with a business need to access personal information to adhere to similar and equally stringent privacy policies. If the Bank uses a third party business partner, service company, or other business partner to prepare account documentation, service accounts, or for other purposes, we will make reasonable efforts to verify the business partner treats customer information in a manner no less stringent than the Bank. All new third party businesses that require non-public personal information on our customers or former customers will be required to meet our privacy requirements before the Bank will engage in business activities.

DISCLOSURE OF PRIVACY PRINCIPLES

It is the policy of the Bank to communicate our privacy policy to our customers. We will periodically review the methods available for communicating the Bank´s privacy policy and determine whether the Bank´s current practices are meeting the needs of the Bank and our customers. The bank will send out their privacy disclosure to all customers of the Bank on an annual basis. In addition, the Bank will give a copy of the privacy disclosure to all new customers of the Bank.

COMPLIANCE

On an ongoing basis the Bank will perform an internal assessment to ensure the privacy policy is in compliance and is being followed
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