As you may well know, Congress has passed the Gramm-Leach-Bliley Act. The GLB deals with how financial institutions treat nonpublic personal financial information. Joseph, Mann & Creed hereafter known as “JMC” understands how important your privacy is to you. This is why we, JMC strongly believe in protecting the confidentiality and security of information we obtain about you. JMC privacy policies and procedures apply only to our company, not to third parties who may handle your personal information.
The Fair Debt Collection Practices Act provides that a debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of debt. Section 807 of the Fair Debt Collection Practices Act provides that "false, deceptive, or misleading representation" includes the failure to disclose in the initial oral or written communication with the consumer that "the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose", and the failure to disclose in subsequent communications that "the communication is from a debt collector". This is referred to as the "Mini-Miranda" Requirement Our internal policy on the Mini-Miranda Requirement exceeds the minimum standards required by law; our policy is that a collector must give the Mini-Miranda to a consumer on each contact made. Collectors are trained to give the Mini-Miranda once they have identified that the person they are speaking with is the correct debtor and prior to discussing the debt or any demand for payment.
Choice and Consent
JMC collects only personal information essential to securing payment of our clients’ receivables. Failure to provide the minimum personal information required to complete a payment may result in further collection efforts from JMC or our clients. By providing JMC with personal information, you are giving JMC implicit consent to use this information for further collections efforts. JMC employees may request your explicit consent prior to collecting sensitive personal information from you. If personal information is to be used for purposes not previously identified in this privacy notice you will be notified. All payment information is protected in accordance with PCI DSS Security Standards and explicit consent is required prior to processing any credit card payments.
Confidential information entrusted to JMC will be secured from unauthorized viewing, accidental distribution, and accidental loss. Confidential information is received in both paper and electronic form. Account information is not purged from our database. Your personal information is kept electronically and any paper containing personal information is disposed of securely. JMC maintains compliance with SSAE 16 security principles such as:
- Employees are authorized to access personal information based on job responsibilities.
- Authentication is used to prevent unauthorized access to personal information stored electronically.
- JMC provides secure processing areas for mail collection, mail opening, payment posting, reconciliation and remittances.
- Physical security is maintained over personal information stored in hard copy form, and encryption is used to prevent unauthorized access to personal information sent over the internet.
- Additional security safeguards are applied to sensitive information.
Parties to Whom We Disclose information
Access to your information
JMC collects information fairly and lawfully from others, such as credit bureaus, affiliates, or other companies. JMC may collect information regarding your whereabouts or financial information from third- party sources. You have the right to obtain certain items of information that we have collected about you. You also have the right to request correction of information if you feel it is not accurate. These requests must be made in writing. If we agree, we will correct our records and may notify our client. If we do not agree, we will be sure to communicate this to you.
Inquiry, Complaint and dispute process
Any inquiries, complaints or disputes should be directed to our corporate compliance officer in writing to the address listed at the end of this policy.