Social Security Privacy Policy

This Policy provides for the confidentiality of social security numbers obtained by the Garmo & Kiste PLC in the ordinary course of business pursuant to pursuant to Section 4 of the Michigan Social Security Number Privacy Act, MCLA 445.81. Any questions regarding this Policy may be directed to Matthew R. Van Steenkiste or Brian F. Garmo.

References in the Policy to “social security number” mean an individual’s social security number or more than four sequential digits of that number. References in the Policy to “documents” include all documents regardless of form (i.e., paper, electronic, microfiche, etc.). References in the Policy to “mail” include electronic mail.

I. Applicability

• Effective July 20, 2008, this Policy applies to all employees of Garmo & Kiste PLC.

II. Access to Social Security Numbers

• Garmo & Kiste PLC restricts access to information or documents containing social security numbers to only its employees who have a legitimate business reason to access such information or documents.

III. Prohibited Disclosures

• This policy prohibits any unlawful disclosure of any social security number in the possession of Garmo & Kiste PLC. Additionally, in efforts to ensure the confidentiality of the social security numbers it has obtained in the ordinary course of business, the employees of the Garmo & Kiste PLC shall not do any of the following with all social security number in its possession:

1. Publicly display the social security number.

1. Use the social security number as an individual’s primary account number.

1. Mail any document containing a social security number that is visible on or from outside the envelope or packaging for the document.

1. Mail a document containing an individual’s social security number unless:

• A State or federal law, rule, regulation, or court order or rule authorizes, permits, or requires that the social security number appear in the document, or;

• The document is mailed in connection with an ongoing administrative use to do any of the following:

• Verify an individual’s identity, identify an individual, or accomplish another similar administrative purpose related to an existing or proposed account, transaction, product, service, or employment.

• Investigate an individual’s claim, credit, criminal, or driving history, or;

• Detect, prevent, or deter identity theft or another crime, or;

• Lawfully pursue or enforce any legal right which Garmo & Kiste PLC might have.

• The document is mailed by or at the request of the individual whose social security number appears in the document or at the request of his/her parent or legal guardian.

• The document is mailed in a manner or for a purpose consistent with the federal Gramm-Leach-Bliley Act (GLB), federal Health Insurance Portability and Accountability Act (HIPAA), or the Michigan Insurance Code of 1956.

IV. Authorized Uses

• This Policy does not prohibit the use of social security numbers where the use is authorized or required by state or federal statute, rule, regulation, or court order or rule, or pursuant to legal discovery or process.

V. Disposal of Social Security Numbers

• Documents that contain social security numbers shall be properly destroyed when those documents no longer need to be retained pursuant to Garmo & Kiste PLC’s document retention policies.

• Paper documents containing social security numbers should be shredded and/or burned.

• Electronic documents containing social security numbers should be destroyed be deleted and/or erased.

VI. Violations

• Violations of this Policy may result in disciplinary action, up to and including dismissal for employees. Individuals who violate this Policy may also be subject to the civil and criminal penalties provided for in the Michigan Social Security Number Privacy Act.