MID SOUTH TITLE SERVICES, LLC
Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution, directly or through its affiliates, from sharing Non-Public Persona Information (NPPI) about you with a nonaffiliated third part 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 the GLBA, we are providing you with this document, which notifies you of the privacy policies and practices of MID SOUTH TITLE SERVICES, a Tennessee Limited Liability Company.
We may collect NPPI about you from the following sources:
– Information we receive from you, over the phone, via email or in person or on forms
– Information about your transactions we secure from our files, or from our affiliates or others
– Information we receive from a consumer reporting agency
– Information that we receive from others involved in your transaction, such as the real estate agent or lender
We may disclose any of the above information that we collect about our customers or former customers to our affiliates as permitted by law.
CURRENT AFFILIATES: NONE
We WILL NOT disclose this information about our customers or former customers to non-affiliated companies that perform marketing services.
WE DO NOT DISCLOSE ANY NPPI ABOUT YOU WITH ANYONE FOR ANY PURPOSE THAT IS NOT SPECIFICALLY PERMITTED BY LAW.
We restrict access to NPPI 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 regulation to guard your NPPI.
ALTA BEST PRACTICES
POLICIES AND PROCEDURES
INFORMATION SECURITY POLICY
– All MST employees and representatives are subject to a Financial and Criminal Background Check to be administered every 36 months
– MST reserves the right to terminate any employees deemed to have not passed the Background Check
HANDLING OF NPPI
– All file documentation must be accounted for at all times
– Only 1 file or pre-file order open at a time
– Only pertinent documentation should be on printed paper in the physically file
– All printed paper to be scanned as soon as possible to the file in Sureclose, with printed paper immediately designated for destruction
– Paper for shredding must be placed in locked bin at end of every day.
– Communication of documents containing NPPI must only occur via Secure Email within Title Workplace, via FEDEX, or via Courier in a sealed envelope.
– Clean Desk Policy:
o 1 File open at a time
o Close files when away from desk
o Screen Saver Return is password protected
o At end of day, all files and documents removed from desk to lockable file cabinet
o Keys for file cabinet stored in locked secure area
o Password List to be maintained electronically, inside of My Documents, inside of TitleWorkPlace
DISTRIBUTION OF NPPI
– NPPI may only be release to the client or Lender directly
– Only MST representatives maybe allowed in secure areas
– Clients, Realtors, Lenders, etc, shall be escorted through any secure areas
REMOVABLE MEDIA POLICY USE
– Without express consent from Management, no MST employee or representative is to connect any removable device or digital storage unit to any MST computers, printers, scanners, copiers, or any MST electronic device. This includes but is not limited to thumb drives, external hard drives, mobile phones
ACCEPTABLE USE POLICY
– Acceptable use of MST hardware and software by MST Staff is as follows:
o Staff may not use MST CPUs or other computerized hardware for any purpose other than the designated workflow process as dictated by MST Procedures.
o Staff may not access any social media sites, unless in expressed assigned situations, such as marketing or advertising for MST. By MST Management designation only.
o Staff may use internet browsers to access webpages in order to complete workflow assignments. Examples would be government tax and info sites, mortgage payoff sites, HOA sites, Realtor – Broker sites, etc.
o Staff may also use internet browsers to visit widely known and safe news and information sites, such as newspapers, tv news sites, internet news sites, etc.
o Staff may also use internet browsers to check personal email. STAFF MAY NOT CLICK ON ANY ATTACHMENT OR EXECUTABLE CONTAINED IN ANY PERSONAL EMAIL, AT ANY TIME, FOR ANY REASON.
o Staff may not save or store any digital information or media on any MST computer or hardware.