Due Diligence and Ongoing Monitoring

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  • 1.  Member Contact List for Credit Union

    Posted 07-09-2020 08:06 AM

    Would you consider a member's list to be non public or public information at a credit union? We have always kept it as our own, but now we are having vendors who need that information. Would you consider the vendors that have to have this information critical now ?​


  • 2.  RE: Member Contact List for Credit Union

    Posted 07-09-2020 09:50 AM

    We consider our customer list (the equivalent of your member list) non-public confidential information.

     

    • If the vendor has access to your member list as part of delivery of their services, their access to it should be covered by the non-disclosure agreement and/or NDA parts of your contract/agreement.
    • If they don't have a need to access the list in order to provide their service, I would question why they are requesting it (and I would probably have concerns about doing business with that vendor if they don't have a "need to know" and are requesting the list)

     

    Hope that helps!

     

    Rosalie Stremple, MS-MIS, CTPRP, CBCP