GENERAL PURPOSE AND PHILOSOPY

The Gramm-Leach-Bliley Act of 1999 established new requirements for financial institutions to provide privacy protection to consumers. At Whidbey Island Bank, our mission is to comply with the requirements of the act and the wishes of our customers. As a financial institution we are entrusted with sensitive financial information. We respect the privacy of our customers and are committed to treating customer information responsibly. Our Privacy Policy serves as a standard for all Whidbey Island Bank employees over the collection, use, retention and security of individual customer information.


Categories of Information We Collect
Categories of Information We Disclose
Confidentiality and Security
Maintenance of Accurate Information
Providing Privacy Information to Customers and Responding to Inquiries
Maintaining Customer Privacy with Third-Party Relationships
Responsibilities
Training
Auditing


CATEGORIES OF INFORMATION WE COLLECT

Whidbey Island Bank collects nonpublic personal information about its customers from the following sources:
  • Information we receive from consumer applications or other forms

  • Information about transactions between us and our customer

  • Information about transactions between our customers and nonaffiliated third parties

  • Information from a consumer reporting agency

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CATEGORIES OF INFORMATION WE DISCLOSE

Whidbey Island Bank does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
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CONFIDENTIALITY AND SECURITY

Whidbey Island Bank is committed to the security of customer financial and personal information. We restrict access to nonpublic personal information on customers to those employees with a business reason to know such information. We maintain and grant access to customer information only in accordance with internal security standards.

Employees are educated on the importance of maintaining the confidentiality of customer information and privacy principles. All employees are responsible for maintaining confidentiality of customer information. Employees who violate the bank's privacy policy will be subject to disciplinary measures.
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MAINTENANCE OF ACCURATE INFORMATION

We continually strive to maintain complete and accurate information about our customers and their accounts. We will respond to customer's concerns about inaccurate information in a timely manner by investigating and correcting inaccuracies.
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PROVIDING PRIVACY INFORMATION TO CUSTOMERS AND RESPONDING TO INQUIRIES

At Whidbey Island Bank, we value our customer relationships. We want our customers to understand how we use the information provided to us and our commitment to ensuring their personal privacy. The bank's privacy procedures will provide for disclosure requirements, timeframes, and otherwise delivery of notices as well as responding to inquires.
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MAINTAINING CUSTOMER PRIVACY WITH THIRD-PARTY RELATIONSHIPS

When we conduct business with third parties, we require our vendors and suppliers to maintain similar standards of conduct regarding the privacy of customer nonpublic personal information provided to them. All third-party agreements will contain contract language protecting the confidentiality of our customer information.
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RESPONSIBILITIES

The Board of Directors acknowledges there is risk involved with non-compliance of this Act. It is the responsibility of the Board to adopt and approve the bank's Privacy Policy and to review on an annual basis. The Board of Directors will appoint a Privacy Officer for the bank. The Privacy Officer will be responsible for overall implementation and monitoring the effectiveness of the privacy program. Each employee has the responsibility of adhering to the bank's Privacy Policy and related procedures.
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TRAINING

The Privacy Officer has the responsibility to ensure ongoing training for all bank personnel. Privacy procedures will address training for new hires and ongoing annual training for all employees.
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AUDITING

Audits will be performed by the bank's Internal Auditor in accordance with the bank's Audit policy. The bank's Audit Committee (which reports to the bank's Board of Directors) will review these audit reports.
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