ID Theft Policy

Safeguarding Consumer Information

Highland Bank maintains internal controls sufficient to protect customer financial information as outlined in our Information Security Policy and procedures.

The Bank’s Information Security Program is designed to:

• Ensure the security and confidentiality of our customer’s information;
• Protect against any anticipated threats or hazards to the security or integrity of such information;
• Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer; and
• Ensure the proper disposal of customer information and consumer information.

Incident Response Handling Program

The Bank maintains a process for internal reporting of suspicious or fraudulent activity, including identity theft. If sensitive personal information is compromised, we will follow the procedures outlined in our Incident Response Handling Program and procedures.

The Bank’s Incident Response Handling Program is designed to:

• Assess the nature and scope of an incident, and identify what customer information systems and types of customer information has been accessed or misused;
• Notify the FDIC as soon as possible when the Bank becomes aware of an incident involving sensitive customer information;
• Notify appropriate law enforcement authorities, in addition, to filing a timely incident reports in situations involving federal criminal violations requiring immediate attention;
• Take appropriate steps to contain and control the incident to prevent further unauthorized access or use of customer information; and
• Notify customers when warranted.

If you think that your identity may have been compromised please follow the recommended steps provided in The Federal Trade Commissions (FTC) website.