IAM Financial, L.L.C. views protecting its customers private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act (the GLBA), IAM Financial, L.L.C. has instituted the following policies and procedures to ensure that customer information is kept private and secure.
This policy serves as formal documentation of IAM Financial, L.L.C.'s ongoing commitment to the privacy of its customers. All employees will be expected to read, understand, and abide by this policy and to follow all related procedures to uphold the standards of privacy and security set forth by IAM Financial, L.L.C.. This Policy, and the related procedures contained herein, is designed to comply with applicable privacy laws, including the GLBA, and to protect nonpublic personal information of IAM Financial, L.L.C.'s customers.
A. Scope of Policy
B. Overview of the Guidelines for Protecting Customer Information
In Regulation S-P, the Securities and Exchange Commission (the SEC) published guidelines, pursuant to section 501(b) of the GLBA, that address the steps a financial institution should take in order to protect customer information. The overall security standards that must be upheld are:
Regulation S-P contains several exceptions, which permit IAM Financial, L.L.C. to disclose customer information (the "Exceptions"). For example, IAM Financial, L.L.C. is permitted under certain circumstances to provide information to non-affiliated third parties to perform services on IAM Financial, L.L.C.'s behalf. In addition, there are several "ordinary course" exceptions, which allow IAM Financial, L.L.C. to disclose information that is necessary to effect, administer, or enforce a transaction that a customer has requested or authorized. A more detailed description of these Exceptions is set forth below.
IAM Financial, L.L.C. may disclose information to nonaffiliated third parties as required or allowed by law. This may include, for example, disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit, or examination, or the sale of an account to another financial institution.
IAM Financial, L.L.C. has taken the appropriate steps to ensure that it is sharing customer data only within the above noted Exceptions. IAM Financial, L.L.C. has achieved this by understanding how IAM Financial, L.L.C. shares data with its customers, their agents, service providers, parties related to transactions in the ordinary course or joint marketers.
F. Safeguarding of Client Records and Information
IAM Financial, L.L.C. has implemented internal controls and procedures designed to maintain accurate records concerning customers' personal information. IAM Financial, L.L.C.'s customers have the right to contact IAM Financial, L.L.C. if they believe that IAM Financial, L.L.C. records contain inaccurate, incomplete, or stale information about them. IAM Financial, L.L.C. will respond in a timely manner to requests to correct information. To protect this information, IAM Financial, L.L.C. maintains appropriate security measures for its computer and information systems, including the use of passwords and firewalls.
Additionally, IAM Financial, L.L.C. will use shredding machines, locks and other appropriate physical security measure to safeguard client information stored in paper format. For example, employees are expected to secure client information in locked cabinets when the office is closed.
IAM Financial, L.L.C. protects confidential client information including but not limited to consumer report or any compilation of consumer report information derived from a consumer report by maintaining some information in locked filing cabinets and shredding such information when then information is no longer needed by IAM Financial, L.L.C.
G. Security Standards
IAM Financial, L.L.C. maintains physical, electronic, and procedural safeguards to protect the integrity and confidentiality of customer information. Internally, IAM Financial, L.L.C. limits access to customers' nonpublic personal information to those employees who need to know such information in order to provide products and services to customers. All employees are trained to understand and comply with these information principles.
H. Privacy Notice
IAM Financial, L.L.C. has developed a Privacy Notice, as required under Regulation S-P, to be delivered to customers initially and on an annual basis. The notice discloses IAM Financial, L.L.C.'s information collection and sharing practices and other required information and has been formatted and drafted to be clear and conspicuous. The notice will be revised as necessary any time information practices change. A copy of IAM Financial, L.L.C.'s Privacy Notice is included at Appendix "D".
I. Privacy Notice Delivery