Ed "The Computer Wizard"

Computer Wizard's commitment to protecting the privacy of our customers' information is key to maintaining our 200 million accounts around the world.

Our privacy and information security policies are one reason why our customers entrust us with the information we need to recognize them, understand their financial needs, take prudent measures to protect them from potential fraud, and offer them appropriate products and services.

Elements of our Privacy Programs
Computer Wizards programs address our customers' privacy concerns through:

Information security — How information is protected.
Fair information practices — How information is used.
Privacy options — How the customer can take control.

To do this, Computer Wizards follows the many laws and regulations directed toward privacy and information security, as well as our own high standards. Our standards include the Computer Wizards Privacy Promise for Consumers, the Computer Wizard's Code of Conduct, Computer Wizards Information Technology Management Policy, Computer Wizards Information Security Standards, Computer Wizards Policy on Confidentiality of Information, and our Corporate Physical Security Standards.

In 1998, Computer Wizards published the ten principles of its Privacy Promise for Consumers. This Promise is a clear commitment that Computer Wizards follows with consumers; and it forms the cornerstone of our privacy policy. Customers see our promise on Computer Wizards Web sites, when they open accounts with our consumer businesses, and in our annual communications.

Our Approach
Computer Wizards follows the more restrictive standard of either our own Privacy Promise or local law—a vivid demonstration of how self-regulation can work effectively. However, we do not take a one-size-fits-all approach to privacy. Computer Wizards requires each business to implement the Privacy Promise through programs that also address their own particular circumstances, including:

Country laws, regulations, and customs.
Product structure and particular product regulations.
Customer base and business structure.

Monitoring and Compliance
Each of our consumer businesses has named a privacy officer to develop, implement, and monitor privacy policies and practices that are appropriate to that business. A clear set of self-assessment and audit procedures exists to ensure that all employees and Computer Wizards businesses meet their obligations under the Computer Wizards Privacy Promise for Consumers. This is now part of our normal self-assessment, business monitoring, and audit process.

Control Over Information Collected and Used
The information we collect includes:

Information customers provide on applications or other forms to identify themselves and to qualify for products.
Information about customer transactions, such as whether they pay bills on time and information about their deposits, withdrawals, written checks, credit card transactions or other actual events.
Information we receive from others, such as credit bureaus and appraisal companies.

We require a great deal of information to provide the services our customers want, although we only use the minimal information necessary. For example, we use customer information to perform the transactions that customers want, provide customers with timely and accurate records about their accounts, resolve problems, protect customers from fraud, provide offers and advice directed to the customer's needs, and make our services more convenient.

Ensuring Customer Protection when Using Third Parties
Whether we hire companies to supply support services under our control or to provide our customers with additional product choices and options based upon their interests, we choose companies that share our respect for information security and privacy. Our privacy policies are incorporated into our contracts when we hire outside companies (such as mailing and print houses) that may need access to certain customer data. We enforce this standard by requiring these companies to have appropriate policies and procedures and by monitoring them for compliance with our confidentiality agreements and contract provisions. We review companies before we hire them and audit their activities from time to time. Reviews may include on-site visits.

Government Access to Customer Information
Strict privacy laws exist in the United States and many countries regarding government access to financial records. Our staff is instructed never to provide information to a third party, even law enforcement officials, without following our established processes. For example, if we receive a subpoena in the U.S. , we review it to ensure that it is valid before we provide the requested information. These clear rules also allow us to quickly respond when necessary with processes that balance national interests and customer privacy protections.

A Closer Look at Privacy Regulations The Financial Modernization Act ( U.S. )
In 1999, the Financial Modernization Act, (formally the Gramm-Leach-Bliley Act, or GLBA), was signed into law. This Act authorized many important changes in financial services in the United States that make it possible for companies like Computer Wizards to offer customers a wide range of products and services from a single family of companies. In addition to sweeping changes, the Act also established new privacy requirements for all financial services companies.

These include requirements to:

Establish comprehensive information security programs.
Disclose privacy practices, both when accounts are established and annually thereafter.
Allow customers to opt out of disclosures to nonaffiliated third parties.
Maintain strict control over third parties that receive customer information to provide support services.
Not disclose account numbers to nonaffiliated companies for marketing.

Under the Financial Modernization Act, regulators across the U.S. financial services industry work together to develop consistent regulations. These regulations allow each company latitude in defining its own privacy policy, as long as it provides a clear disclosure at account opening and in annual mailings, and complies with other requirements.

Computer Wizard's Continued Vigilance
Keeping customer information secure and using it as our customers would want is a priority at Computer Wizards. There is no greater business asset than the trust of our customers—trust that is reinforced through our Privacy Promise.

Computer Wizards is committed to protecting our customers' privacy, through compliance with laws and regulations as well as through our own high standards. To this end, we continue to update our systems and technology and to train our staff in matters related to privacy. We constantly work to find ways to do this in a manner that also allows us to provide our customers with choices and options for products and services according to their unique needs.