PRIVACY OF CONSUMER FINANCIAL
INFORMATION POLICY
Integrity Bank
April 2006

Integrity Bank (the Bank) values the trust our customers place in us. The Bank is committed to ensuring the security and confidentiality of customer information and protecting that information. Information about our customers is held in confidence by the Bank. No employee of Integrity Bank shall divulge any non-public information of a customer or discuss the business of a customer with anyone outside the Bank without the customer’s prior written consent or as permitted by law.

It is the policy of Integrity Bank to comply with all requirements imposed on the Bank by the Gramm-Leach-Bliley Act of 1999 regarding the safeguarding of customer information. The Bank follows its established standards for administrative, technical and physical safeguards of customer records.

Integrity Bank has established an Information Security Policy that is designed to protect against anticipated threats to the integrity of such information and against unauthorized access to that information. The Policy also includes:

• Written procedures approved by the Board of Directors of Integrity Bank

• Periodic testing to identify internal and external threats

• Procedures to assess and monitor risks that may threaten customer information

• Methods for adjustment of the information security program

• A breach of security response system

The Board of Directors of Integrity Bank annually approves the information security program and monitors the program through periodic reports from the Information Security Officer.

It is the policy of Integrity Bank to review the measures the Bank has taken to safeguard customer information. The review takes into account the on-going changes in technology and the internal and external changes that the Bank goes through. Not only is the focus on compliance with this part of the Gramm-Leach Bliley Act but also on the legal ramifications that arise from noncompliance.