Title V of the Gramm-Leach-Bliley Act (GLBA) generally
prohibits any financial institution, directly or through its affiliates, from
sharing nonpublic personal information about a consumer with a nonaffiliated
third party unless the institution provides the consumer with a notice of its
privacy policies and practices, such as the type of information that it collects
about the consumer and the categories of persons or entities to whom it may be
disclosed.
In compliance with the GLBA, we do not share nonpublic personal
information about a consumer with a nonaffiliated third party, unless allowed by
law.
In compliance with
the GLBA, our privacy practices regarding nonpublic personal financial information of consumers and
customers (as defined by GLBA) are as follows, subject to any exceptions as permitted by
law.
- We protect nonpublic personal information of
customers and consumers.
- We allow access on need to know basis only. Only
title company personnel who need to know can access the information. Examples
may include bookkeepers, title examiners, title underwriter personnel,
auditors, closers and their assistants, management, scanning personnel, and
claims related investigation personnel, including but not limited to retained
counsel.
- We allow customers and consumers to review their
nonpublic personal information that we have collected, and we allow them to
provide us with requests for amendment or deletion of such information, to
which we will reasonably respond.
- We require consent from a proper party to the
transaction to provide nonpublic personal information relating to tha1t
transaction. On closed files, we require a written instruction by a party.
- We have implemented a security procedure for
protection of nonpublic personal information: we allow only authorized
personnel to review the information, and we keep closed files in secure
storage, with limited access, or we store the files on computer with limited
password access.
- We generally do not keep copies of credit reports,
loan applications, and tax returns on consumers and customer.').
- We don't share copies of owner's policies of
customers on residential transactions, unless at the request of the insured
owner. If we share starter title information, we don't share nonpublic
personal information, ,such as sales price (unless it is public information),
policy numbers, or amount of insurance on owner's policies issued to
customers.
- We don't share nonpublic personal information, such
as social security numbers, shown on affidavits of identity.
- We periodically inform our personnel about our
policy.
We don't share nonpublic personal information with
independent contractors, unless there is a need to process the transaction as
allowed by law, and the contractors agree in writing not to further share the information.
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