Direct Mortgage Loans, LLC
Chapter 1 Introduction
Before Company collects personally identifiable information (“PII”)*, customers are notified that such information is being collected, why it is being collected, and how it will be used. Company only collects the minimum amount of PII necessary to achieve the task. In the event Company collects more PII than necessary, the information is returned, or it is destroyed in accordance with Company policy. The company works to ensure that the PII on record is accurate, relevant, timely, and complete. The company holds itself accountable for handling PII appropriately and trains all of our employees to make sure they know how to ensure that PII remains protected.
Chapter 2 Commitment to Privacy
At Direct Mortgage Loans, LLC, has nine privacy principles that guide when and how PII is collected, used, shared, and protected.
- Purpose of collection
Direct Mortgage Loans, LLC will state the purpose and legal authority for collecting PII.
- Openness and transparency
Direct Mortgage Loans, LLC will notify customers as to the PII collected from them, as well as how it will be protected, use it, and shared. A convenient way for customers to learn about what is happening to their PII will be provided.
- Data minimization
Direct Mortgage Loans, LLC will limit the collection of PII to what is needed to accomplish the stated purpose for its collection. Direct Mortgage Loans, LLC will keep PII only if needed to fulfill its stated purpose.
- Limits on uses and sharing of information
Direct Mortgage Loans, LLC will provide notice about how it is planned to use and share the PII that has been collected. The company will only use or share PII in a manner compatible with the notice, as stated in the Privacy Act, or as explicitly mandated or authorized by law.
Direct Mortgage Loans, LLC collects identifying information for a contact list when borrowers submit an online application or inquiry via the website or app. The following information may be collected at application: name, address, phone number, email address, financial information, and employment information. Additional information may also be requested. All personal and financial data collected is used for the purpose of checking the borrowers’ qualifications for a residential mortgage loan. Direct Mortgage Loans may use third party intermediaries to manage the website functionality and information submitted, however they are not permitted to store, retain, or use the information except for the purpose of facilitating the functionality of website. In addition, we collect phone contacts in the mobile app when you share the app.
Direct Mortgage Loans neither rents nor sells borrower’s personal information. Sharing of personal information is only with third parties that assist in the marketing, processing, funding, servicing and or sale of the mortgage loan. Third parties may include, but are not limited to, title companies, credit companies, appraisers, insurance companies, underwriting services, and purchasers of loans.
All borrower information collected is maintained in a secure corporate data center subject to best practices. Only employees who need customer information to perform their job are given such access. All employees are kept up to date with privacy and security practices.
- Access to Information Using the App
When using our mobile app, the borrower may be prompted to allow access to their phone’s contact list. Direct Mortgage Loans does not use this list for the purpose of marketing or any other type of contact. The permission is solely for the app’s functionality.
- Data quality and integrity
Direct Mortgage Loans, LLC will make reasonable efforts to ensure that all PII it maintains is accurate, relevant, timely, and complete.
Direct Mortgage Loans, LLC will protect PII from loss, unauthorized access or use, destruction, modification, or unintended or inappropriate disclosure.
- Individual participation
Direct Mortgage Loans, LLC will, in most cases, give customers the ability to access their PII and allow them to correct or amend it if it is inaccurate.
- Awareness and training
Direct Mortgage Loans, LLC will train all Company employees about how to secure PII properly to ensure that it remains protected.
- Accountability and auditing
Direct Mortgage Loans, LLC will ensure accountability in the handling of PII through strict policies and procedures communicated to all Company employees. Independent auditors hold the Company accountable for complying with these policies and procedures. The company also
conducts its own internal audits to ensure that responsibilities are being met and takes swift and immediate action if any violations of law or our policies or procedures are uncovered.
Chapter 3 Chief Privacy Officer
Direct Mortgage Loans, LLC’s Chief Privacy Officer (“CPO”) is the Company’s Senior Official for Privacy, and is responsible for overseeing, coordinating, and facilitating the Company’s compliance efforts in accordance with applicable privacy requirements in statute, regulation, and policy. The CPO evaluates the privacy implications of legislative, regulatory, and other policy proposals and ensures that the technology used by Direct Mortgage Loans, LLC upholds privacy protections. The CPO manages privacy risks associated with all Company’s activities that involve the creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal of PII. The CPO is responsible for ensuring that all employees are familiar with information privacy laws, regulations, policies, and procedures and
understand the serious consequences and ramifications of inappropriate access, use, or disclosure of PII.
The CPO ensures completion of System of Records Notices (“SORN”), Privacy Impact Assessments
(“PIA”), and provisions of appropriate privacy notice. The CPO is also responsible for ensuring that Direct Mortgage Loans, LLC takes steps to eliminate unnecessary collection, maintenance, and use of Social Security numbers, and explore alternatives to the use of Social Security numbers as a personal identifier. The CPO and the privacy program are an important part of a comprehensive approach to effective acquisition and management of Company information resources.
Chapter 4 Training Company Employees
Direct Mortgage Loans, LLC trains all employees to maintain strict confidentiality, protection, and respect for PII they encounter in the course of their duties.
The CPO provides specific training for all operational units that handle PII.
Chapter 5 Limiting Access to Information
Direct Mortgage Loans, LLC only allows access to PII to authorized individuals with legitimate need-to- know access.
Company employees will:
- Only access PII as authorized and as needed to carry out official
- Disclose PII only as authorized by
- Ensure that they protect and dispose of PII in accordance with applicable laws, regulations, and Company policies and procedures. This includes:
- Storing all digital customer PII in cloud-based loan origination PII necessary for the origination and closing of loans will be retained for a minimum of three years, unless otherwise mandated by a specific law or regulation. Additionally, Company complies with all local, state, and federal requirements for document retention.
- Temporary collection of hard-copy PII will be stored in fireproof filing cabinets before it is uploaded to secure servers. Once uploaded, hard-copy PII is either returned to the customer or disposed of through locked shredder bins.
- Unapproved storage methods include:
- USB Thumb Drives
- Email inbox or other email file folders including trash or archived folders
- Mobile Devices (Including Non-Company issued Cell Phones)
- Personal Email Inboxes
- External Hard Drives
- Personal Computers (Not issued by Direct Mortgage Loans)
- Only use PII for the purposes it was collected unless other purposes are explicitly mandated or authorized by law.
- Establish and maintain appropriate administrative, technical, and physical safeguards to protect
Company system owners and managers will:
- Meet all responsibilities for employees related to PII as outlined
- Follow applicable laws, regulations, and Company policies and procedures in the development, implementation, and operation of information systems under their control.
- Conduct a risk assessment to identify privacy risks and determine the appropriate security controls to protect against This includes safeguards, such as encryption, to prevent unauthorized access to, loss of, or theft of laptops and/or other portable media devices including thumb drives, portable hard drives, cell phones, etc.)
- Ensure that only the minimum PII that is necessary and relevant for legally mandated or authorized purposes is collected.
- Ensure that disposal of PII complies with this policy including:
- Professionally wiping laptops, hard drives, thumb drives, or servers before disposal
- Hard-copy PII is either returned to the customer or disposed of in locked shredder bins when no longer needed.
- Monitor existing safeguards to ensure that all customer PII is safe and not at risk of exposure to unauthorized parties
- Active company safeguards include:
- All office locations are locked and secured; only accessible by company issued badges
- Visitors must be rung in by reception and escorted to their destination
- Encryption of any email containing sensitive data
- Company issued laptops are encrypted upon distribution
- Company issued laptop USB drives are disabled
- Passwords for computers and laptops must be changed every 60 days
Chapter 6 Third Parties
The company will ensure that PII is either transmitted through encrypted emails or a secure portal that is established for the express purpose of transmitting PII securely.
*The Office of Management and Budget has defined “Personally Identifiable Information” as
“information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other information that is linked or linkable to a specific individual.” Office of
Management and Budget, M-17-12, Preparing for and Responding to a Breach of Personally Identifiable Information, Jan. 3, 2017. Direct Mortgage Loans, LLC has adopted this definition in its entirety for the purposes of this policy and the Company’s Data Classification.
Chapter 7 Policy Revision History
02/24/2023Updated and ReviewedErin Naylor3
|Revision/Annual Review Date||Description of Revision||Approved By||Revision|
|?||Policy Created||?Erin Naylor|
|9/1/2021||Active Safeguards||Erin Naylor||1|
|1/22/2023||Updated and Reviewed||Erin Naylor||2|
|02/15/2023||Updated and Reviewed||Erin Naylor||3|
|02/24/2023||Updated and Reviewed||Erin Naylor||4|