The Privacy Act of 1974, 5 U.S.C. § 552a establishes a regulation that governs the collection, maintenance, use, and dissemination of personally identifiable information about individuals that is maintained in systems of records by federal agencies. The Privacy Act requires that agencies give the public notice of their systems of records by publication in the Federal Register (DOJ Systems of Records). The Privacy Act prohibits the disclosure of information from a system of records absent the written consent of the subject individual unless the disclosure is according to one of twelve statutory exceptions. The Privacy Act also provides individuals with a means by which to seek access to and amendment of their records and sets forth various agency record-keeping requirements.
The protection of our client’s privacy and confidentiality is a priority to our firm. To do so, we are serious about maintaining electronic, physical and procedural safeguards that comply with legal standards to safely store and secure our client’s information from unauthorized access and use. Our policies and procedures have been developed and are constantly updated to protect an individual’s confidentiality and to help maintain compliance with relevant rules and regulations. The members and associates of our firm are held accountable for complying with said policies, procedures, rules and regulations.
We collect and use our client’s information only for appropriate purposes, what we believe will assist us with delivering the highest level of service, to preside over our business, manage our risks, promote our services and products, and to meet all relevant laws and regulations. We share some information about our clients with affiliates, business units and with others when we believe it will enhance the services and products we can provide to our clients or for legal and routine business reasons but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, our policies, and practices, or where a client has consented to such sharing.
We may disclose the information we have about clients as permitted by law. As an example, we may provide information to regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by law and to provide information to protect against fraud. From time to time, we enter into agreements with other entities to provide services to us or make services and products available to clients. Under these agreements, we may share information about clients, but they must safeguard this information and they may only use it for those purposes that are specified by said agreements. In these cases, we will disclose to our clients about the sharing of information with our affiliates and/or others.
We will give clients choices regarding the sharing of information with affiliates and third parties following applicable law and their agreements with us.