Corporate One Federal Credit Union ("Corporate One") is one of the nation's largest corporate credit unions and it is committed to providing competitive and innovative products and services for the success of credit unions. In fulfilling its mission, Corporate One has access to nonpublic information about its member credit unions and their members. Corporate One values the protection of personal information and its use in a confidential manner, consistent with the requirements of its member credit unions.
Corporate One takes every reasonable precaution to protect the accuracy and integrity of nonpublic information. Corporate One restricts access to nonpublic information to employees with a specific business purpose for use of the information. Corporate One has established security procedures and security levels controlling employee access, as well as physical and electronic safeguards, which comply with existing regulations and which conform with standard industry practices to safeguard information.
Corporate One's policy is to satisfy all laws and regulations concerning the use and disclosure of nonpublic personal information about its member credit unions and their members. Recently, changes have occurred to the legal framework governing disclosure of nonpublic personal information, including the adoption of the NCUA Privacy Regulation, 12 C.F.R. Part 716 (the "NCUA Privacy Regulation"). A corporate credit union has somewhat different obligations under the NCUA Privacy Regulation than does a natural person credit union. Under the NCUA Privacy Regulation, as a recipient of nonpublic personal information from its member credit unions, Corporate One is prohibited from disclosing or using that information for any purpose other than the purpose for which the information was disclosed to Corporate One by its member credit unions. Compliance with the NCUA Privacy Regulation is required by July 1, 2001.
Accordingly, in light of Corporate One's policy to comply with all laws and regulations concerning the disclosure of nonpublic personal information, the Board of Directors of Corporate One, on April 26, 2001, adopted a policy that it will disclose nonpublic information only as permitted by the NCUA Privacy Regulation.
Therefore, in consideration of the services to be rendered in the future by Corporate One under its service contracts and for other good consideration, effective as of June 1, 2001, Corporate One's service contracts with its member credit unions shall be deemed to have been amended to state that Corporate One will not disclose nonpublic personal information except in conformity with the NCUA Privacy Regulation.
This statement shall serve as evidence of this amendment to all of Corporate One's existing service contracts, instead of written amendments to each contract. If a member of Corporate One does not accept this amendment, it should notify Corporate One of its nonacceptance by June 1, 2001. If a member of Corporate One uses any of Corporate One's services after the date of this statement and does not notify Corporate One by June 1, 2001, of its nonacceptance of this amendment, then it shall be conclusively deemed to be in agreement with this amendment of its service contracts with Corporate One and no further written amendment to the service contracts of the member will be prepared.
Under the NCUA Privacy Regulation, federally insured members of Corporate One may have an obligation to provide privacy notices to their own members and to non-members in connection with the delivery of financial services and products and, accordingly, federally insured members of Corporate One should carefully consult the NCUA Privacy Regulation regarding their disclosure obligations.
Privately insured members of Corporate One should carefully consult the Privacy Regulation of the Federal Trade Commission regarding their disclosure obligations.
Information is the cornerstone of our ability to provide superior service and our most important asset is our members' trust. Keeping member information secure, and using it only as our members would want us to, is a top priority for all of us at Corporate One.