It is the policy of BBN to handle the relationship between BBN and its client banks with strict confidence. It is a fundamental business principle of the banking industry and of banking laws that all information, documents, and records maintained and transacted are confidential. It is the policy of BBN that we do not share information provided to us or processed by us with any unaffiliated third party except as permitted by regulation.
As a service provider, BBN may receive non-public personal information (NPPI); in accordance with regulation the Bank’s disclosure and use of the information is limited as follows:
- The Bank may only disclose NPPI as necessary to affect, administer or enforce a
transaction requested or authorized or in connection with servicing or processing a
previously authorized transaction;
- The Bank may not use the information unless the use would be permitted in accordance with the exceptions; and
- The Bank may not disclose information to any other person/entity not affiliated with the Bank, unless the disclosure would be permitted by exceptions per Regulation or other law.
With respect to any agreements that BBN may enter into with respondent banks or other service providers, and to the extent that BBN receives from its respondent banks, non-public personal information (as such is defined under Title V of GLBA, 12 CFR, and other applicable state laws and regulations), BBN shall not disclose or use any such non-public personal information other than to carry out the purpose for which such information was disclosed by the respondent bank to BBN or as otherwise allowed by law.
BBN will ensure compliance with all legal requirements under the privacy regulations
regarding contractual agreements with non-affiliated third parties which have been provided with or have access to NPPI. Such agreements will prohibit the reuse and disclosure of NPPI unless such disclosures would be permitted by exceptions per the privacy regulations or other applicable laws as well as the proper disposal of such information.
Our web server maintains a log to indicate the date and time users have visited the site and what pages they have visited. We recognize and respect the privacy of our customers and other visitors and we use the information only to assess the level of interest in the Web Site.
The Bank has conducted a self-assessment in an effort to identify reasonable, foreseeable, internal and external threats that could result in unauthorized disclosure, misuse, alteration, or destruction of customer information or systems. Management has also reviewed the sufficiency of policies, procedures, customer information systems, and other arrangements in place to control risks.
EMPLOYEE ACCESS AND INFORMATION SECURITY
BBN only allows access to NPPI to those employees who have a specific business reason to know such information in regards to the delivery of our products and services. If the policies or procedures concerning privacy are violated, disciplinary action will be taken.
BBN has developed an Information Systems Policy and an Information Security Policy and has security procedures in place to prevent unauthorized access to your NPPI.
BBN shall employ physical, electronic and procedural safeguards over the storage, retention and destruction of NPPI in compliance with applicable laws, regulations and guidelines.
EMPLOYEE TRAINING AND AWARENESS
All employees receive training relative to privacy related policies, issues and practices on a periodic basis. In addition, employees are required to acknowledge receipt of the Bank’s Acceptable Use Policy.