What You Need to Know
- What information is collected from clients;
- What sources that information is collected from (over and above information provided by the client);
- The firm’s basis for sharing this information;
- What safeguards you have in place to protect client information; and
- Any state-specific privacy regulations the firm is subject to.
Why You Should Care
Identify theft, cyber fraud and high profile security breaches have become common occurrences. The media attention they receive has undoubtably heightened your clients’ sensitivity to protecting their personal information.
As a general policy, supervised persons should not release confidential client information without first consulting with the CCO. This mitigates your regulatory risk by ensuring that nonpublic information is disclosed only to the extent it is needed to conduct business for that client.
To ensure that your firm is keeping up with regulatory requirements and industry best practices in this area:
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