The Compliance Officer is responsible for assuring that appropriate written procedures and internal controls are adopted within each operating area of the bank to assure customer financial privacy. Each department and branch has internal controls to assure that customer information is dispensed only as allowed or required by law or regulation. Departmental compliance audits conducted by the Internal Auditor must include a review of privacy related issues in each appropriate subject area. This review shall incorporate compliance with the general philosophy of this policy as well as the specific requirements of law or regulation. All employees are alerted to the level of confidentiality required in banking relationships during new employee orientation and must acknowledge receipt of a copy of this policy.
Training incorporates privacy-related issues in each appropriate subject area.
Maintenance of the confidentiality of customer information is a primary responsibility of all bank personnel. Breaches of confidentiality are addressed in the employee handbook and can serve as the basis for dismissal. All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The board of directors of The First National Bank of Livingston approved and adopted this policy on April 11 2001. First National Bank.