Sources of Information
- Information provided by you
- Information provided by third parties such as other advisers or financial institutions, family members, doctors or medical facilities.
- Information provided by publicly-available sources.
Such information may be in verbal, electronic or written format. We use reasonable means to verify the accuracy of information obtained from sources other than you. We assume that information provided by you is accurate and fully disclosed.
Who We Share Information With
- Current legally married spouses. We freely share information with the current legal spouse of a client. We consider current husband and wife to be a “joint client”. This policy is effective even though we may only require one spouse’s signature on our client agreement.Any information that we communicate to one spouse is considered to be relayed by the recipient to the other spouse.It is your responsibility to notify us promptly of any marital status change and/or electronic mail address change(s). References in this privacy statement and in our client agreement and advisor disclosure form to “you” or “client” refer to either husband or wife or both.
- Parties that you give us express written consent to share information with, in the course of working with you.
- Any law or regulatory authority, if required.
Electronic Information Storage
We may store some information, such as planning documents, investment statements, meeting and conversation notes and other items electronically. Such information may be stored on “local” workstations as well as on “cloud-based” internet servers.
Local workstation data is encrypted and password protected. “Cloud-based” services that we use employ a password protection and minimum 128 bit SSL encryption to protect your information. Additionally, several services may provide additional security, such as server-level data encryption and/or 24/7 on-site security. All client sensitive data is redacted, whether kept on local workstation or on a cloud-based service.
We believe we have taken reasonable measures to ensure the safety of your data. However, should we become aware of a security breach that might compromise your personal information, our policy is to notify you promptly.
Non-Electronic Information Storage
We may also maintain physical files with client data inside our office. We follow reasonable measures to protect such documents, including the use of locked file cabinets and offices.
We consider social security numbers, account numbers, dates of birth and specific health-related conditions to be confidential information, and we will not send these items electronically without using a password-protected document and/or encrypted e-mail or similar means.
We consider financial information such as account types, account values, statements of financial condition and specifics related to your financial plan (i.e., assumptions, recommendations and illustrations) as semi-confidential. This means we may use unprotected electronic means to communicate such items to you but we will not communicate such information directly to other parties (except as detailed above). In short, you agree that for such semi-confidential information, the ease of using unsecured electronic communication outweighs the possibility of such information being intercepted by others.
We may use third party internet-based communication services firms to communicate with clients. An example is the vendor which we use to share our firm’s client newsletter. By providing us with your e-mail address, you give us permission to communicate with you via e-mail and via such services. We will not give away, share or sell your e-mail address to any other third parties.
Employees and Contractors
This privacy statement applies to all officers, employees and contractors of our company. Whenever possible, we limit employee and contractor access to certain information, and we use reasonable measures to prevent the unauthorized release of your information.