(701) 663-5362

PRIVACY POLICY NOTICE

 

PURPOSE OF THIS NOTICE


Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution, direly or through its affiliates, from sharing non-public information about you with a nonaffiliated third party unless the institution provides you with a notice of its privacy policies and practices, such as the type of information that it collects about you and the categories of persons or entities to whom it may be disclosed.  In compliance with GLBA we are providing you with this document, which notifies you of the privacy policies and practices of The North Dakota Guaranty and Title Co.

We may collect nonpublic personal information about you from the following sources:

  • Information we receive from you such as on applications or other forms;
  • Information about your transactions we secure from our files, or from The North Dakota Guaranty and Title Co.
  • Information we received from a consumer-reporting agency;
  • Information that we receive from others involved in your transaction, such as the real estate agent or lender.

Unless it is specifically stated otherwise in an amended Privacy Policy Notice, no additional non-public personal information will be collected about you.

We may disclose any of the above information that we collect about our customers or former customers to our affiliates or to nonaffiliated third parties as permitted by law.

We also may disclose this information about our customers or former customers to the following types of non-affiliated companies that perform marketing services on our behalf or with whom we have joint marketing agreements: 

  • Financial service providers such as companies engaged in banking, consumer finance, securities and insurance
  • Non-financial companies such as envelope stuffers and other fulfillment service providers.

WE DO NO DISCLOSE ANY NON-PUBLIC PERSONAL INFORMATION ABOUT YOU WITH ANYONE FOR ANY PURPOSE THAT IS NOT SPECIFICALLY PERMITTED BY LAW.

We restrict access to non-public personal information about you to those employees who need to know that information in order to provide products or services to you.  We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your non-public personal information.

ACT 113-1



Data Breach Response Policy

1.0 Purpose

The purpose of the policy is to establish the goals and the vision for the breach response process. This policy will clearly define to whom it applies and under what circumstances, and it will include the definition of a breach, staff roles and responsibilities, standards and metrics (e.g., to enable prioritization of the incidents), as well as reporting, remediation, and feedback mechanisms. The policy shall be well publicized and made easily available to all personnel whose duties involve data privacy and security protection.

The North Dakota Guaranty and Title Company including d.b.a’s Grand Forks Abstract and Title, Strander Abstract and Title, Pennington Abstract and Title, Becker County Title Services, Consolidated Abstract Company and Consolidated Title Services, herein after “NDGT” Information Security's intentions for publishing a Data Breach Response Policy are to focus significant attention on data security and data security breaches and how NDGT’s established culture of openness, trust and integrity should respond to such activity. NDGT is committed to protecting NDGT's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.   

1.1Background

This policy mandates that any individual who suspects that a theft, breach or exposure of NDGT protected nonpublic personal information (NPI) has occurred must immediately provide a description of what occurred via e-mail to IThelpdesk@thetitleteam.com or by calling (701) 420-9602. This e-mail address and phone number are monitored by the NDGT’s Information Security Administrators. This team will investigate all reported thefts, data breaches and exposures to confirm if a theft, breach or exposure has occurred. If a theft, breach or exposure has occurred, the Information Security Administrator will follow the appropriate procedure in place.

2.0 Scope

This policy applies to all whom collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle NPI of NDGT customers and clients.

3.0 Policy Confirmed theft, data breach or exposure of NDGT protected NPI

As soon as a theft, data breach or exposure containing protected data is identified, the process of removing all access to that resource will begin.

The President will chair an incident response team to handle the breach or exposure.

The team will include members from:

  • IT
  • Finance (if applicable)
  • Legal Counsel
  • Communications
  • The affected offices and departments that use the involved system or output or whose data may have been breached or exposed
  • Additional individuals as deemed necessary by the President
  • Additional departments based on the data type involved

Confirmed theft, breach or exposure of NDGT held NPI

The President will be notified of the theft, breach or exposure. IT, along with the designated forensic team, will analyze the breach or exposure to determine the root cause.

Work with Forensic Investigators

As may be provided by NDGT cyber insurance, the insurer may provide access to forensic investigators and experts that will determine how the breach or exposure occurred; the types of data involved; the number of internal/external individuals and/or organizations impacted; and analyze the breach or exposure to determine the root cause. 

Communication and Response plan.

The NDGT President, communications, legal counsel and human resource departments will decide how to communicate the breach to: a) internal employees, b) those directly affected, and c) the public as needed. NDGT will immediately communicate the plan determined above which may include, if enough individual information was compromised, the cost of identity protection for the harmed individual. The service provided of identity protection will be selected at the sole discretion of NDGT.

3.2 Ownership and Responsibilities

  • Sponsors - Sponsors are those employees, generally office managers, and IT contractors of NDGT that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by the President in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.
  •  Information Security Administrator is the employee of the NDGT, designated by the President, who provides administrative support for the implementation, oversight and coordination of security procedures and systems with respect to specific information resources.
  •  Users include virtually all employees of NDGT that have access to information resources, and may include, contractors, consultants and temporary employees.
  • The Incident Response Team will be chaired by the President and shall include: IT, Communications, Legal, Human Resources and Accounting.

4.0 Enforcement

Any NDGT personnel found in violation of this policy may be subject to disciplinary action, up to and including termination of employment. Any third party partner company found in violation may have their relationship with NDGT terminated.

5.0 Definitions

Encryption or encrypted data – The most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted data is called plain text;

Plain text – Unencrypted data.

Hacker – A slang term for a computer enthusiast, i.e., a person who enjoys learning programming languages and computer systems and can often be considered an expert on the subject(s).

Nonpublic Personal Information (NPI) – personally identifiable financial information (i) provided by a consumer to a financial institution, (ii) resulting from any transaction with the consumer or any service performed for the consumer, or (iii) otherwise obtained by or from the financial institution. Such term does not include publicly available information, as such term is defined and prescribed under section 505 [15 USCS 6804].

Information Resource - The data and information assets of an organization, department or unit.

Safeguards - Countermeasures, controls put in place to avoid, detect, counteract, or minimize security risks to physical property, information, computer systems, or other assets. Safeguards help to reduce the risk of damage or loss by stopping, deterring, or slowing down an attack against an asset.

6.0 Revision History

Version

Date of Revision

Author

Description of Changes

1.0

June 29, 2017

Nick Hacker

Initial version