OCTOBER 2022
Summary
This Privacy Policy (“Policy”) establishes directives and guidance regarding information privacy.
Purpose
To ensure that The Weld Trust (TWT) protects the privacy of personal or confidential information belonging to TWT and others.
Responsibilities and Authorities
The Chief Executive Officer (CEO) will be responsible for the implementation of this Policy. Accordingly, the CEO will develop and implement necessary operating procedures in connection with any policy matter. Operating procedures and any revisions will be reviewed by the Leadership team with final approval by the CEO.
This Policy will be reviewed and evaluated for compliance annually or at any time if requested by the Board. Such reviews may be performed by Leadership or independent third parties having appropriate qualifications and expertise. The findings of any evaluation will be reported to the Board.
Commitment to Privacy
TWT will be sensitive to the privacy or confidentiality of certain information in the TWT’s possession or under its control. TWT acknowledges that information in its possession may belong or relate to individuals or entities separate and distinct from TWT. The CEO will have authority to identify information which will be considered private or confidential.
Information Collected
TWT will collect the least amount of private or confidential information necessary to carry out the business activities of TWT or as required by law.
Information Protection
TWT will restrict or limit the ability to access, use or transfer information that it considers private or confidential. TWT will provide access to private or confidential information to authorized individuals who have a legitimate business need for such access in order to perform or conduct business activities of TWT.
TWT will take reasonable measures to protect private or confidential information utilizing physical, electronic, and procedural safeguards.
Authorizations to Release Information
TWT may share private or confidential information with third parties who use the information in performing certain business activities requested by TWT. When that is the case, a clause will be included in TWT’s contract with the third party which requires them to implement appropriate measures to safeguard the information and to refrain from sharing any information with any other party without TWT’s permission. In addition, TWT will share private or confidential information with third parties if required by law or regulation.
TWT will identify those circumstances which require the use or disclosure of private or confidential information. In these cases, TWT will take reasonable and necessary actions to obtain the permission of the individual or organization. TWT will use its best efforts to obtain written authorizations or consents to use or disclose the identified information.
Sale/Distribution of Information
TWT will not sell or otherwise provide any private or confidential information in its possession to any third party for purposes which are not related to TWT’s business activities.
Website/Social Networking Sites
Use of TWT’s website or other internet-based social networking sites will be permitted with the approval of the CEO.
The CEO will develop and incorporate appropriate disclosures which include privacy expectations and use statements pertaining to any information TWT receives online. These disclosures will be reviewed annually by CEO for any necessary modifications.
Compliance with Legal Requirements
TWT will stay informed and knowledgeable about any federal or state privacy laws or regulations applicable to TWT and will take requisite actions to comply with such laws or regulations.