Smart TITLE AND ESCROW, LLC
Title V of the Gramm-Leach-Biley Act (GLBA) generally prohibits any financial institution, directly or through it 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 policies and practices, such as the type of information 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 customer(s) and consumer(s).
- We allow access on a need to know basis only. Only title company personnel who need to know can access the information. Examples may include bookkeepers, title examiners, closers and their assistants, management, scanning personnel, and claims related investigation personnel.
- We allow customers and consumers to review their nonpublic personal information that we have collected, and we allow them to provide us with their 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 that 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 a locked storage, with limited access, or we store files on computer with limited password access.
- We generally do not keep copies of credit reports and tax returns on consumers and customers.
- We do not 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 do not share nonpublic personal information, such as sales price (unless it is public information), policy numbers, or amount of insurance on Owner’s Policies issued by customers.
- We do not share nonpublic personal information, such as social security numbers, shown on affidavits of identity.
- We periodically inform our personnel about our policy.
- We do not 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.