General Policy Statement:
The Credit Union recognizes its responsibility to safeguard and protect the nonpublic personal information of our members, and in some circumstances non-members. The purpose of this policy is to set forth guidelines under which such information may be shared with third parties, the circumstances in which we will provide disclosures to our members regarding the sharing of such information, and the measures employed to protect and keep such information confidential. It is the intent of the Credit Union to abide by all applicable laws and regulations governing privacy, including but not limited to National Credit Union Administration Regulation 716 (Privacy of Consumer Information).
Guidelines:
1.Collection of Information: The Credit Union will only collect information that is necessary to conduct its business. In the course of delivering products and services, the Credit Union obtains nonpublic personal information from its members, and in some circumstances from non-members. The information is necessary to either comply with a state or federal law or regulation, or to provide effective and competitive services.
2.Member Access: The members of Credit Union will have access to all information the credit union maintains that is related to them individually. Members do have a responsibility to protect their nonpublic private information.
3.Maintenance of Information: The Credit Union takes reasonable steps and will implement procedures to assure that member information it gathers is accurate and maintained in a manner to assure its accuracy. In the event inaccurate information is discovered, the Credit Union will correct the inaccuracy as promptly as possible.
4.Sale of Information Prohibited: It is the policy of Credit Union not to sell member information to third party under any circumstances.
5.Sharing of Account Number Prohibited: It is the policy of the Credit Union not to share any account numbers or similar access numbers of its members or non-members except as required or authorized by law or in accordance with paragraph 7 of this policy.
6.Disclosure of Information to Third Parties: In an effort to provide products and services and to comply with state and federal laws and regulations the Credit Union does share nonpublic personal information with third parties. Such information sharing is done in compliance with applicable laws and regulations, including providing required notices to members that such information sharing takes place. Good Shepherd Credit Union does not use "cookies". ( A cookie is a file placed on your hard drive by a Web site that allows it to monitor your visit, usually without your knowledge.) You can set your browser to warn you when placement of a cookie is requested and decide whether or not to accept it.
7.Responsibility of Third Parties: The Credit Union selects its service partners with due diligence and care. If the Credit Union will share information with a service partner, such service partner will only be approved if it has established privacy policies that are consistent with the privacy policies of the Credit Union and the laws and regulations governing privacy. Where appropriate the Credit Union will protect nonpublic personal information for any other purpose that for which the Credit Union provides the information to the service partner. The Credit Union will consult with legal counsel to assure contracts it enters are in compliance with the laws and regulations governing privacy.
8.Notice of Information Sharing: The Credit Union will provide members (and when applicable non-members) with initial and annual notices related to privacy policies and practices as required by law or regulation, including where appropriate an opportunity to “opt-out” of information sharing. It is the intent of the Credit Union to properly record and honor all requests from members to “opt-out”.
9.Non-Member Consumer Information: In some instances the Credit Union obtains nonpublic personal information from persons that are not members of the credit union, but are consumers of its products or services. Much of the information the Credit Union obtains is necessary to complete a transaction or is required for compliance with law or regulation. It is the policy of the Credit Union to use this information solely for the purpose which it is obtained either from the consumer directly or from a third party, and not to disclose it to any third party for any purpose.
10.Information About Former Members: In the event a person who was a member of the Credit Union is no longer a member, the Credit Union will maintain only that information which is necessary to provide products or services that person is receiving from the credit union at the time of becoming a non-member, as required by law or regulation, and consistent with the Record Retention Policy of Credit Union, or for the purpose of contacting the non-member regarding reestablishing membership in the credit union.
11.Internal Security and Privacy: Credit Union maintains a comprehensive risk management system to protect the credit union and its members. This system is intended, in part, to ensure safety and confidentiality of member records, protect against anticipated threats or hazards to the security of such records, and protect against unauthorized access to or use of records that could result in substantial harm or inconvenience to a member or the credit union. Where appropriate security coding and other available technology will be used to protect against unauthorized access to personal records, ensure accuracy and integrity of transactions and communications, and protect confidentiality.
Credit Union will restrict access to nonpublic personal information it obtains to only those employees who have a specific business purpose for accessing and utilizing such information. All employees will be trained to maintain the confidentiality and privacy of all personal information.
Protecting Children's Privacy Online
The Children's Online Privacy Protection Act (COPPA) was passed by Congress in October 1998, with a requirement that the Federal Trade Commission (FTC) issue and enforce rules concerning children's online privacy. The primary goal of the Act and the Rule is to place parents in control over what information is collected from their children online. The Rule was designed to be strong, yet flexible, to protect children while recognizing the dynamic nature of the Internet.
What These Privacy Rules Mean to YOU:
Good Shepherd Credit Union is committed to protecting the privacy of children (and everyone) who visits the Early Bird site. You probably noticed that we don't ask you for your name, we don't ask you for your e-mail address, and we don't have a chat room where other people can ask you for personal information.
Why don't we care about all of your personal information? Because we want you to be a safe cyber-surfer…and we want you to have fun and learn while you're at our site or in our branch. That's all…just have some fun and learn a few things!
Security
Good Shepherd Credit Union will protect the confidentiality of its customers' information, account information and personal communications to the fullest extent possible and consistent with the law and the legitimate interests of Good Shepherd Credit Union, its partners, its employees and other customers of Good Shepherd Credit Union's services. To guard against the loss, misuse, and alteration of information that is collected from customers, Good Shepherd Credit Union has appropriate physical, electronic, and managerial procedures in place.
Good Shepherd Credit Union's Web hosting servers are 'hardened' against hackers with proprietary tools, OS tweaks, network procedures and constant monitoring. This is not a guarantee that a hacker could not succeed.
Through Verio, we have System Administrators that are dedicated to Web hosting security. They insure that we are current with all OS security patches. We have very high-level software maintenance contracts with our Vendors (SGI, Cisco, Foundry) so that we are sure to have the latest patches and support staff available to us 24x7x365 for fixes.
Security audits are run regularly on our servers. This supplements our internal efforts to keep our servers as protected as possible. We do record and monitor illegal port accesses both on the networking hardware and the servers. We log all accesses to our servers that allows us to check the accesses for intrusion attempts. Additional technologies are also used to ensure notification of any active attacks. For Denial of Service attacks, a new procedure that our System Administrators implemented called "ipfilterd" allows us to block attacks directed at a single Web site on a server rather than a network level giving us better granularity. "spamd" is another tool used to minimize the effect of attacks on the system - specifically email. Blocking spam makes us less of a target for those hackers that target Spammers. We also have the following implemented services:
- Triple data backup
- Accessible 24-hour user volume backup
- Regularly scheduled digital tape backups
- Each Virtual Server resides in a protected sandbox
- Potentially insecure programs are disabled or removed
- Hacking alert system immediately notifies system administrators
- Redundant OC12, OC3, and DS3 Internet connectivity
- Cisco routers and switches
- Redundant power backup
- 24/7 data center monitoring
- Security hardened operating systems
E-SIGNATURE DISCLOSURE/AGREEMENT
This is a disclosure required by the Federal Electronic Signatures in Global and National Commerce Act (E-Signature Act) in order for us to provide you with disclosures and make agreements with you on-line. Please read this disclosure carefully prior to clicking on the "I Accept" button below. We recommend that you print a copy of this disclosure and maintain a copy for your records.
By clicking on the "I Accept" button you agree to the following terms and conditions:
* You agree to the acceptance of notices, periodic statements, and disclosures by means of electronic delivery.
* You understand and agree that you have a right to receive any required notices, periodic statement, and disclosures in paper form as well as your right to withdraw your consent to have them delivered electronically.
* You further understand and agree that in order to withdraw such consent you must provide Good Shepherd Credit Union with notice either in writing at Good Shepherd Credit Union, 4111 Fort Street, Lincoln Park, Michigan 48146 or via e-mail.
* Once you have provided your consent to receive notices, periodic statements, and disclosures electronically, you can still obtain paper copies of them by requesting such copies in writing or via e-mail as described above. You agree to pay a per-page fee for paper copies of such documents.
* In order to access GSCU @Home and to receive required notices, periodic statements and disclosures electronically, you will need Internet access and either Microsoft Explorer version 6.0 or higher or Netscape Navigator or Communicator version 6.0 or higher, and you must enable JavaScript in your browser.
* You agree to notify Good Shepherd Credit Union immediately of any change in your e-mail address in writing or vie e-mail as described above.
* You agree that by clicking on "I Accept" below, you have reasonably demonstrated your ability to access information in the electronic form that will be used to provide you with required notices, periodic statements and disclosures.
Your online transactions with us will be governed by separate agreements with us that provide access to GSCU @Home and/or bill payment services. Your acceptance of those separate agreements will, however, be in accordance with this disclosure.

Good Shepherd CU
4111 Fort Street
Lincoln Park, Michigan
48146
313.386.9220
Fax: 313.386.4317
mbrsvc@goodshepherdcu.org
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