Policy
All nonpublic customer information, including non-public information relating to former or inactive customers, shall be kept confidential and shall only be disclosed to third parties as a result of a transaction or service performed for the customer, or, as required by law.
Practices
- Access Restrictions. Zeliff Wallace Jackson Investment Counsel will restrict access to customers' personal and account information only to its employees and non-affiliated outside parties where it is necessary to carry out its services for the client.
- Security. All hard copy files containing customer non-public information are to be maintained in secured file cabinets on premise, or, off premise, in a commercial archive facility only accessible by authorized staff appointed by Zeliff Wallace Jackson Investment Counsel. All documents or correspondence containing customer non-public information will be destroyed or shredded prior to disposal. Access to the Company's computer network, whether local or remote, will be password protected; all employees' computers will be password protected. Computer back up tapes containing customer non-public information will be stored utilizing the Company's accounting vendor offsite storage procedure.
- Confidentiality Practices. Zeliff Wallace Jackson Investment Counsel will discuss confidentiality practices with each of its employees upon hire and maintains adherence to these policies and practices as a condition of employment.
- Business Service Providers. Zeliff Wallace Jackson Investment Counsel will require those companies providing business services to Zeliff Wallace Jackson Investment Counsel, that might come into possession of non-public customer information, execute a confidentiality agreement.
|