BREWERY CREDIT UNION PRIVACY POLICY (CONT)
MANAGEMENT AND CONTROL OF RISK
- Establish procedures designed to implement, maintain and enforce the credit union's information security program. See E-Commerce Policy.
- Limit access to the credit union's member information systems to authorized employees only.
- Establish controls to prevent employees from providing member information to unauthorized individuals.
- Limit access at the credit union's physical locations containing member information, such as buildings, computer facilities, and records storage facilities to authorized individuals only.
- Provide encryption of electronic member information including but not limited to information in transit or in storage on networks or systems to which unauthorized individuals may have access.
- Ensure that member information system modifications are consistent with the credit union's information security program.
- Implement dual control procedures, segregation of duties, and employee background checks for employees with responsibilities for or access to member information.
- Monitor the credit union's systems and procedures to detect actual and attempted attacks on or intrusions into the member information systems.
- Establish response programs that specify actions to be taken when the credit union suspects or detects that unauthorized individuals have gained access to member information systems, including appropriate reports to regulatory and law enforcement agencies.
- Implement measures to protect against destruction, loss, or damage of member information due to environmental hazards, such as fire and water damage or technical failures.
- Regularly test, monitor, evaluate, and adjust as appropriate, the information security program in light of any relevant changes in technology, and internal or external threats to the credit union's information security systems.
- Regularly test the key controls, systems, and procedures of the information security program.
- Ensure that all contracts with service providers contain appropriate provisions requiring the service providers to protect the confidentiality of the credit union member's nonpublic personal information.
EMPLOYEE TRAINING
Employees should be trained with regard to their responsibilities under this policy. In addition, employees should be trained to recognize, respond to, and where appropriate, report any unauthorized or fraudulent attempts to obtain member information.
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