As general policy, Second Phase Capital (“SPC”) will not disclose personal financial information about any client to non-affiliated third parties except as necessary to establish and manage the client’s account(s) or as required by law. In these situations, personal financial information about a client may be provided to the broker/dealer or other custodian maintaining these accounts.
In addition, SPC restricts access to a client’s non-personal financial information to those who need to know such information in order to provide products or services to clients. SPC maintains physical, electronic, and procedural safeguards that comply with federal standards to guard each client’s personal financial information. A hard copy of client personal financial information is maintained in SPC’s central files, and is secured (locked) after normal business hours. Electronic access to client personal financial information is restricted to the investment adviser representatives handling the client’s account through SPC’s local area network (LAN). Electronic LAN access is available to persons with a legitimate business need for access to such information.
- The Firm may collect nonpublic personal information about the Firm’s clients and potential clients from the following sources:
- Information received from account applications, written questionnaires, interviews/conversations, information forms and other client interactions;
- Information about transactions with the Firm, any affiliates of the Firm, or others; and
- Information the Firm obtains or receives from a consumer reporting agency.
- All client information is to be maintained in the Firm’s master client files and/or stored on appropriate electronic media. Information from potential clients may be filed in temporary files, but shall be subject to the same restrictions and limitations as other client files outlined below.
- Firm personnel are prohibited from sharing or disclosing nonpublic information regarding any client or potential client of the Firm, except (i) as necessary to service client accounts including, without limitation, the settlement, billing, processing, clearing, or transferring of client transactions; or (ii) as otherwise directed by a client. Access to all client files and information, whether in paper or electronic format, is limited to Firm personnel for the purposes of servicing client accounts.
- Firm personnel may not remove client files or information from the Firm’s premises unless (i) it is necessary to service client accounts; and (ii) prior approval is obtained from the Chief Compliance Officer.
- All client files are secured at the end of each business day, and exterior doors always remain locked.
- All computers are set up so they ‘lock’ when not in use, requiring a password to gain access.
- Traffic flow in the office is restricted, and no individuals, other than employees, are allowed free access to areas where client information is held.
- Employees working remotely must utilize passwords to gain access to the Firm system servers or other cloud computing system.
- The Firm shall deliver an updated Privacy Notice to all of its clients annually, even if the notice has not changed since the previous year.
- A copy of the Firm’s current Privacy Notice is available on request.
- SPC has undertaken to protect client information in the course of its disposal as well. Employees either utilize personal desk-side shredders or place material to be shredded in a secure retention container.