Pinehurst Bank Privacy Statement

Your Privacy, and How We Protect Information About Your Pinehurst Bank Account

At Pinehurst Bank we believe the confidentiality, protection and integrity of customer information is one of our fundamental responsibilities.  While information is critical to providing quality service, we recognize that one of our most important assets is our customer’s trust.  Therefore, we accept our responsibility to safeguard their information.

Our policy will apply to all users of customer information. 

Users are defined as individuals having access to customer information, whether it is in the electronic or non-electronic information environment.  Users include Pinehurst Bank and affiliate employees (present, temporary and/or former), clients, customers, consultants and vendors.  For the purposes of this policy, any reference to customers or customer information is understood to include both customer and customers as defined in the Gramm-Leach-Bliley Act (GLB Act), Interagency Guidelines for Safeguarding Customer Information and subsequent regulations.

       Pinehurst Bank will comply with the provisions of the GLB Act of 1999, Interagency Guidelines for Safeguarding Customer Information and subsequent regulations.

       Pinehurst Bank will always value the trust of its customers and recognize the importance of keeping their personal financial information confidential.

       Pinehurst Bank will collect and use information about individual customers only when we reasonably believe it would be used (and allowed by law) in administering Pinehurst Bank’s business and in providing products, services and other opportunities to our customers.

       Pinehurst Bank will establish procedures to maintain accurate information and to respond in a timely manner to our customer’s request to change or correct information.

       Pinehurst Bank will hold users of customer information to the highest standards of conduct in an effort to ensure the confidentiality of such information while at the same time providing quality products and services.

       Pinehurst Bank will comply with appropriate provisions of the GLB Act of 1999, Interagency Guidelines for Safeguarding Customer Information and subsequent regulations by establishing and using a combination of standards designed to administratively, technically, and physically safeguard customer records and information from anticipated threats and hazards, and from unauthorized access.

       Pinehurst Bank will limit disclosure of information about customer accounts or other personally identifiable data to only those situations where disclosure is necessary for providing products or services or as permitted by law.

       Pinehurst Bank will perform appropriate due diligence when selecting third party vendors to perform services for the Bank that may require disclosure of customer information.

       Pinehurst Bank will develop and maintain a Consumer Privacy Statement.  This statement will serve as the Bank’s public disclosure of its privacy policy.

       Pinehurst Bank will provide consumers with our Consumer Privacy Statement as required by the GLB Act of 1999, Interagency Guidelines for Safeguarding Customer Information and subsequent regulations.

       Any person may make a comment or complaint about Pinehurst Bank’s Consumer Privacy Statement, any privacy-related issue or an inaccuracy in customer data by contacting the Bank.  Employees receiving such comments or complaints will either respond to the customer or escalate the issue within the Bank as appropriate.

       Enforcement of this policy applies to three general areas:

w  ENFORCEMENT OF EMPLOYEE AWARENESS:  Pinehurst Bank will include consumer privacy in its formal Information Security Training program.

w  ENFORCEMENT OF POLICY PROVISIONS:  Department managers and supervisors will work in conjunction with the CIO to enforce all provisions of this policy.

w  ENFORCEMENT OF CONSEQUENCES:  Department managers and supervisors will work with Human Resources as appropriate to enforce consequences due to non-compliance.  Non-compliance with this policy may result in disciplinary action, up to and including termination.

       Pinehurst Bank will perform audits of Pinehurst Bank’s actual practices against this policy according to its published audit schedule.  Findings will be reported according to Internal Audit Policy.