In accordance with Title V of the Gramm-Leach Bliley Act (GLB) also known as Regulation S-P, Semaphore is required to provide an initial privacy notice to each new customer. Furthermore, we are required to adopt procedures to protect the security and confidentiality of our clients’ personal information.
Sharing Client Information
All information that is provided to Semaphore is considered personal and confidential. We do not sell your information to any party. Client information is limited to only those employees and independent contractors who need access to the information either to provide client services or to conduct firm operations. In order to provide the cross-service benefits Semaphore prides itself on, client information is shared by Semaphore employees within each Semaphore division (for example a Semaphore Investments employee may share information with a Semaphore Tax employee). In addition, from time to time, a Semaphore employee may be required to share information with an independent contractor or other party who is necessary to complete a particular transaction. For example, information may be shared with independent contractor mortgage loan processors or escrow agents in order to complete an evidence of insurance for a client.
Semaphore will not give out personal client information over the phone, in response to an electronic communication or correspondence unless our employee or contractor has identified the person to whom the are speaking as either the client, a fiduciary representative of the client, or a party that needs the information to complete a transaction for the client, e.g., broker/dealers, custodians or escrow officers. In the case of a fiduciary representative, we obtain prior verbal consent from the client before giving out any information. With respect to professionals (accountants or attorneys) whom have an ongoing relationship with a client, Semaphore may accept written authorization from the client to provide ongoing information until such time as the client provides written notice that the relationship with the fiduciary has been terminated. We require prior consent from you before we will refer you to an unaffiliated professional where non-public personal information (even your name and phone number) is provided to the professional. No one may provide client information, other than to service providers or designated professionals, without prior approval from us.
Each Semaphore employee will take the following precautions and measures to protect client information:
- Client information will not be left unattended in offices or conference rooms.
- Maintain client records in locked cabinets or desks when not in use.
- Make sure all client records are secured at the end of the day.
- Lock doors and secure offices at the close of business.
- Grant after-hour access to the corporate offices only with manager approval.
- Destroy or shred records or documents containing client information before disposal.
- Store computer passwords where others cannot find them; change passwords periodically; and avoid simple, easy to guess passwords.
- Make sure access to client information through the computer network is limited only to those employees who need this information to service clients or conduct firm operations.
Clients Who Reside in California
California Civil Code 1798.85 (2001) prohibits certain uses of social security numbers. Semaphore does not perform any of the following:
- Publicly post or display in any manner an individual’s social security number. “Publicly post” or “publicly display” means to intentionally communicate or otherwise make available to the general public.
- Print an individual’s social security number on any card required for the individual to access products or services provided by Semaphore.
- Require an individual to transmit his or her social security number over the Internet unless the connection is secure or the social security number is encrypted.
- Require an individual to use his or her social security number to access an Internet Web site, unless a password or unique personal identification number or other authentication device is also required to access the Web site.
- Print an individual’s social security number on any materials that are mailed to the individual, unless state or federal law requires the social security number to be on the document to be mailed. Notwithstanding this provision, applications and forms sent by mail may include social security numbers.
We respect the trust that you place in us and we work hard to ensure that it is protected.