An important part of the relationship we have with our clients is the information they share with us. We want each client to know how we treat their private information.
We generally attempt to avoid the receipt of personal information such as Social Security Numbers and account balances; however, we cannot always avoid what is sent to us. When we do receive personal information, we keep it confidential. We take steps to safeguard this data from anyone who should not have access to it. We do not sell this information to anyone.
In dealing with Access Retirement Solutions LLC and its affiliates, Access Plans LLC and Access Fiduciary Services, LLC (“AFS”) (the “Access Group”), clients can expect that we will take the steps outlined below to keep all their information confidential and secure.
In providing financial services to our clients, we may collect or receive certain non-public information about them or their employees. Our policy is to keep this information confidential and strictly safeguarded, and to use or disclose it only as needed to provide services to them, or as permitted by law. Protecting the privacy of our clients and their employees is important to us.
The non-public personal information we may receive about clients and their employees includes what we are provided by them when they join an Access pooled employer plan or when they communicate with us. This could include:
Names and addresses
Social Security Numbers
Investment objectives and experience
Account balances and account transactions
We do not disclose personal information about our clients or employees to third parties, other than the third parties that provide specific services to, or on behalf of, the Access pooled employer plans. We may disclose anonymous information that cannot be linked to an individual client or its employees on occasion, but only to companies that have been retained to provide services to, or on behalf of an Access pooled employer plan, our clients, or their employees, or as required by law, or as authorized by the client or its employees personally.
We do not sell the personal information of a client or its employees to anyone.
We use information about our clients and their employees to provide our services to them and the Access pooled employer plans. We may disclose this information to third parties as permitted by law, including broker-dealers, custodians, administrators, transfer agents, accountants or attorneys that we may need to use to provide our services. From time to time, we must give information about our business to regulatory authorities. This may, or may not, include personal information about our clients and their employees, and their respective accounts.
We have procedures in place that we believe are reasonably designed to protect the security and confidentiality of client information. These include confidentiality agreements with companies we hire to help us provide services to clients, password-protected user access to our computer files, and strict confidentiality policies that apply to all Access Group personnel, vendors and contractors.