The Federal Trade Commission (FTC) issued Rule 16, C.F.R., Part 14 as required by Title 5 of the Gramm-Leach-Bliley Act to establish standards relating to the administrative, physical and technical safeguards for service providers subject to the Commission’s jurisdiction.
As a provider of image technologies, products and services that serve financial institutions, AccuSystems LLC recognizes its responsibility for:
- Maintaining the integrity of any non-public confidential information provided to us, and
- Safeguarding the privacy of our customers and our customers’ customers to whose information we may have limited access.
AccuSystems LLC does not provide services to the general public. Normally, personal and confidential information is not collected in the course of normal business activities. We do not transact and we do not store in any capacity any non-public confidential information in the document image and loan portfolio management process.
In the process of implementing an advanced loan document imaging and portfolio management system, Genesis Banking platform may require the intervention of AccuSystems’ personnel to successfully install and maintain the software. In that event, AccuSystems’ personnel, on a need-to-know basis only, may have access to non-public confidential information. This information is temporarily housed during the implementation process on a server at mindSHIFT Technologies, a SAS 70 certified data center, and is used for conversion purposes only and is available only from the FI’s core processors’ servers and is not downloaded to any remote server maintained by AccuSystems.
With respect to any agreements that AccuSystems LLC may enter into with it customers and to the extent AccuSystems LLC receives from its customer, non-public personal information (as such term is defined under Title 5 of the Gramm-Leach-Bliley Act, 15 U.S.C. s. 6801 et.seq. and the applicable regulations), AccuSystems LLC 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 its customer. AccuSystems LLC shall restrict access to such non-public personal information to those persons who need to know that information to provide services pursuant to those agreements and who are bound by obligations of confidentiality at least as strict as those set forth herein. AccuSystems LLC shall maintain physical, electronic and procedural safeguards that comply with federal regulations to guard such non-public information.
We also require other companies who provide services on our behalf to enter into agreements that protect the confidentiality of any customer information we provide and to restrict the use of such information to those purposes.
COLLECTION OF NON-PUBLIC PERSONAL INFORMATION – FTC 16 CFR Part 314 loosely interpreted generally prohibits any service provider, directly or through its affiliates or related parties, from sharing non-public personal information about customers or potential customers and their customers with a non-affiliated party except for the purposes of the agreement for services between the provider and customer. In compliance with the applicable rules and regulations of the GLBA and FTC we are providing this document, which notifies our customers of potential customers of the privacy policies and practices of AccuSystems LLC.
WHY WE COLLECT INFORMATION – We may have access to non-public personal information about customers or their customers for the sole purpose of imaging, installing, converting or otherwise rendering the services provided by AccuSystems LLC to our customer if the collection of the information is necessary in order to render those services.
HOW WE DISCLOSE INFORMATION – Non-public personal information that we may have access to is not disclosed to any other parties.