STATEMENT OF PRIVACY POLICY

I. Regarding Mortgage Foreclosure Notices
Berrien County Record is in the business of publishing a legal newspaper of general circulation. Berrien County Record’s business activities include the publication of news relating to the legal profession and of notices of legal actions and proceedings requiring publication in a newspaper of general circulation. Among such notices are notices of mortgage foreclosure for publication as required by applicable statute. The content of the notices to be published and the directions to publish them, are provided by customers based on information known only to Berrien County Record customers. When provided to Berrien County Record, the notices are intended to be published, and Berrien County Record receives them on that basis.
This Statement covers information submitted to Berrien County Record by customers for the purpose of publication and related foreclosure activities.
The information that is Confidential information or Internal Use information (as those terms are defined in the Berrien County Record Clean Desk/Clear Screen Standard) shall not be disclosed to any persons other than those to whom Berrien County Record considers necessary to effect a service that it has been instructed to perform or to facilitate or consummate business transactions with third persons. These persons include employees of Berrien County Record, and its officers and legal counsel, and third person vendors.
If a client of Berrien County Record directs Berrien County Record not to publish Confidential information, Berrien County Record shall order those to whom such Confidential information has been disclosed to delete the data from the hard drives of any individual PCs, laptops, notebooks, netbooks, tablets, pad PCs, PDAs, smart phones or other individual computing devices. Hard copies of Confidential information, including unpublished notices of mortgage foreclosure, are shredded in a controlled shredder. A record of such Confidential information may be retained as a separate file in the archives of Berrien County Record as a normal part of its business practice, but accessible only by a password known to [Level A personnel], and managed by the Director of Information Technology. Employees of Berrien County Record and third persons to whom Confidential information or Internal Use information has been disclosed are instructed not to make further disclosure of such information in any manner as long as it is Confidential information or Internal Use information.
Additionally, all personally identifiable information received from third parties in connection with orders for publication, except for the content of notices submitted for publication, will be treated in the same manner as set forth in general Privacy Policy of Berrien County Record, and which may be modified as set forth in that policy.
The purpose of this policy is to retain privacy of unpublished information. Once published as requested by a client, the information published is no longer subject to privacy. Customers are expressly discouraged from sharing any information with Berrien County Record that is not to be published.
II. Regarding Foreclosure Sale Documents
Foreclosure sale documents (sheriff’s deeds and bidding instructions) delivered to Berrien County Record are not Confidential information or Internal Use information. They are subject to safekeeping and due care standards applicable to all customer documents, but when delivered are intended for public sale and are not private. If Berrien County Record is instructed not to deliver a foreclosure sale document to the selling officer, the documents shall be disposed of in the Berrien County Record shredder. Supporting affidavits of Berrien County Record and its vendors relating to publication and posting may be retained by Berrien County Record in its files or provided to the customer, but are not themselves Confidential information or Internal Use information.