Privacy Statement
1.0 Purpose
McCoy Myers & Associates, a CSI Company (MCM), recognizes the importance of protecting the privacy of our clients. We have created this privacy statement to demonstrate our commitment to privacy and to inform our clients and potential clients of our guidelines regarding information that we acquire during the course of conducting our business.
2.0 Scope
McM provides data processing and specialized programming services for commercial banks. Along with leasing bank software to banks, McM operates three data centers that meet the data processing needs of commercial banks. In addition, McM provides support activities for our clients. The MCM Privacy Statement covers all locations and pertains to all personnel.
3.0 Privacy Statement
MCM maintains information regarding our client’s customers. MCM has established information system (IS) security measures to protect against the loss, misuse, and alteration of the information under our control. MCM‘s website may provide links to other sites. MCM is not responsible for the privacy practices or the content of any other web sites to which we link.
Employees have access to the client and the client’s customer data on a need-to-know basis. We have established policies and procedures to ensure that the client’s and the client’s customer’s financial information is accurate, current, and complete in accordance with reasonable business standards. We also respond to requests to correct inaccurate information in a timely manner. We maintain rigorous security standards and procedures designed to prevent unauthorized access to customer information.
4.0 Collection of Information
MCM collects, retains and uses individual client information only when we reasonably believe it would be useful and allowable by law to administer to our business needs in providing products, services, and other opportunities to our clients and potential clients. The data centers, during the normal course of providing data processing services, maintain account information about the client’s customers.
5.0 How the Information is Used
Information collected on clients is used to conduct the business that the client has contracted from McM. Information about the client’s customers is only used to assist in helping the client regarding an issue with the client’s customer. McM personnel have access rights to the information collected on a need-to-know basis.
6.0 Employee Access
MCM limits our employees’ access to non-public personal information to only those with a business reason for knowing such information. Department Managers are responsible for ongoing employee training so they understand the importance of customer confidentiality and privacy. Employees are required to sign an acknowledgment of all MCM policies and procedures. The signed acknowledgments will be filed in the employees’ personnel files held by the department managers.
7.0 Account Information Disclosure
MCM does not share, sell, or rent potential clients or client’s customers’ accounts or other non-public personal information to unaffiliated third parties. There are however, exceptions that we must honor on behalf of our clients:
- The information is provided to help complete a client-initiated transaction.
- The client requests it.
- The disclosure is required by or allowed by law (e.g. subpoena; the investigation of fraudulent activity, bank regulatory agencies).
- The client has been informed about the possibility of disclosure among affiliated companies for marketing or similar purposes through a prior communication and is given the opportunity to decline.
8.0 Third Party Relationships
Whenever MCM outsources services, we insist that the third party adhere to similar privacy principles for keeping such information confidential. On contracts dated after approval of this statement, MCM will make every effort to include a clause requiring compliance with this statement.
When McM provides services to client Bank’s third party vendors, the client Bank will assume responsibility for due diligence and management of their selected vendor including adherence to privacy principles and regulations.
9.0 Enforcement
Any employee found to have violated the policies and procedures that support this statement may be subject to disciplinary action, up to and including termination of employment.
10.0 Policy Changes
If this Privacy Statement should change, MCM will notify its clients via the MCM website (www.mccoymyers.com) and WebSecure.
11.0 Contact Information
The Executive Vice President may be contacted for questions or comments about the MCM Privacy Statement:
James S Ferguson
McCoy Myers & Associates
6200 Bell St.
Amarillo, Texas 79109
E-mail: james.ferguson@mccoymyers.com