Privacy Notice & Disclosure to Members
The directors, management, and staff of Members First 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 privacy policy and disclosures outline our 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 NCUA's Rules and Regulations. Our credit union's policy regarding security of member information is set forth in Members First Credit Union's general policies.
Types of Information the Credit Union Will Collect
At Members First 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.
Any information that Members First Credit Union collects is stored using a cookie that is placed on your computer. We do NOT use this cookie to collect or store personally identifiable information about you. However, the cookie is used to track information about how you interact with our website. It also allows our website to be customized to meet your interests.
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Types of Information the Credit Union May Disclose
Members First Credit Union may disclose the following types of information about current or former members to non-affiliated third parties:
- Identification information, such as name, address, and telephone number
- Transactional information
- Deposit or loan account experience
The types of businesses these parties represent are:
- Insurance companies
- Data processing companies
- Check printers
- Credit, ATM, debit card vendors
- Collection firms
- Audit firms
- Mortgage appraisal and title companies
- Lending product vendors
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Safeguarding Member Information
At Members First 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, who is responsible for maintaining internal procedures to ensure that our members' information is protected. For example, information in loan files can be accessed only by employees who work in the loan origination or loan operations departments.
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 and the appropriate department managers will take disciplinary action against any employee who violates the credit union's privacy policy and procedures.
If we change our policy or practice by, 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.
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A Member's Right to Opt Out of Sharing Agreements
Members have the right to opt out of the credit union's sharing agreements with certain non-affiliates by completing this form and returning it to the credit union.
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.
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Exceptions to a Member's Opt Out Rights
By law, Members First Credit Union may share personal information about members without allowing the opportunity to opt out in the following circumstances:
With companies that perform 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 account as part of a private label credit card or other loan extension program.
- In connection with a secularization, secondary market sale (including servicing 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 a member's 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's compliance with industry standards, and the credit union's attorneys, accountants, and auditors.
- To the extent permissible under the Right to Financial Privacy Act (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.
Members First Credit Union may also disclose personally identifiable information to nonaffiliated third parties we engage to market our own services or products to members. The credit union will not provide members' 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, nonaffiliated 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 the confidentiality of the information in the same manner the credit union would and restrict its use.
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