Privacy Policy
Background
Personal financial advising and investment management relationships involve the disclosure of private information concerning assets and liabilities, as well as income. It is of the utmost importance that all employees be continually aware of the need to keep al client information private, including the identity of clients. Clients expect that their affairs shall remain private and it is an affirmative duty upon all employees that the clients' desire in that regard be fully met.
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Regulations
The company is aware of the Federal Trade Commission rule requiring financial institutions, including state-registered investment advisors, to ensure the security and confidentiality of client data, effective May 23, 2003.
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Employees of the Company and associated companies are committed to the provisions of the Ghram-Leach-Bliley Act (the "Privacy Act") passed in November 1999. This Act applies to SEC-registered investment advisors under Regulation S-P. The Privacy Act specifically identifies three groups of individuals: non-consumers, consumers, and customers.
Definitions
Non-consumers
Non-consumers, such as prospects and professional firms (CPAs, attorneys), are provided our Privacy Statement as part of the marketing pocket folder that we send in advance of an initial meeting.
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Consumers
When a prospect wills out a set of Fact-Finding Data Sheets whereby they begin to disclose nonpublic personal information, they become consumers. The information provided in the Fact-Finding Data Sheets is not disclosed to any non-affiliated third party, so there is no need for an opt-out opportunity.
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Customers
Client agreements affirm that the client has received a copy of the Company's Form ADV Disclosure Statement, which includes the Privacy Statement language to reinforce our commitment to client privacy. In addition, the Privacy Act requires the annual delivery of our Privacy Statement (not merely an offer to send, as with Form ADV) to all customers. Annually, with the Fall newsletter, clients (customers) are sent a copy of our Privacy Statement.
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Personal Information
Personal Information is defined as the first name (or first initial) and last name, combined with:
Social security number; or
Drivers license number or state-issued ID card number; or
Financial account number, or credit card or debit card number (with or without PIN)
Variations​ of the definition by state exist, but the above is fairly inclusive.
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Confidential Information
Confidential information encompasses a larger set of information than personal information, including, but not limited to: all personally-identifiable information, such as names of clients or prospects and their family members, social security numbers, dates of birth, drivers license numbers, passport numbers, custodians, account numbers, names and securities, custodian numbers of shares of securities, gains or losses on securities, custodian statements, tax return information, insurance policies, cash flow statements, retirement plan statements, estate planning documents, stock option statements, and similar highly-sensitive information.
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Requirements
All reasonable steps shall be taken to assure that personal information and confidential information (collectively, "client information") be kept private. No disclosure of client information shall be made to anyone within the office to whom such disclosure is not necessary for the purpose of accomplishing the work requested. It is prohibited to discuss any client information with anyone not authorized outside the office, including spouses, family or social friends.
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Client information includes the identity of clients. There should not be any disclosure of either the identity of clients or the nature of their business with the firm, or of any information regarding their assets, liabilities, income, or estate planning details.
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Information Security Officer
The Chief Compliance Officer is responsible for the execution of the policies and procedures relative to client privacy and security of client information.
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Employee Integrity
Prospective employees must submit a personal credit report to the President prior to receiving an employment offer. The President may also order a background check on the prospective employee before an employment offer is made.
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When employees leave the Company, the Information Security Officer shall remove or disable computer accounts and change passwords.
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Employee Indoctrination
New employees are required to read the Compliance Manual to ensure that they fully understand their responsibilities for safeguarding client information. Employees acknowledge the Company privacy policy by signing an Employee Privacy Policy Acknowledgement form.
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Training
Annually, employees are trained in the Company privacy policy rules and the necessity to maintain adequate procedures to safeguard client information. Annually, each employee acknowledges his/her understanding of the firm's Privacy Policy and his/her ongoing commitment to safeguarding confidential private information when he/she signs the Employee Privacy Policy Acknowledgement form contained at the end of this Section.
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Monitoring
The Information Security Officer performs ongoing monitoring of data integrity in the normal course of day-to-day business operations.
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Annual Delivery
The master list of clients to whom the Privacy Notice has been sent each Fall is maintained in the archive filing area of the office, along with the list of people to whom the quarterly newsletter was mailed.
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The record of whom the Privacy Notice was sent to is contained electronically in S:\HSWM - ADV Part II & Privacy Notice\HSWM - ADV Part II & Privacy Notice YYYY.
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Enforcement
Violation of the firm's Privacy Policy is cause for dismissal.
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References
Schwab Compliance Review, August/September 2006 issue, "Theft and the Need for Information Security"
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Schwab Compliance Review, August 2007 issue, "Regulation S-P: Now More Important Than Ever"
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