Safeguarding Customer Documents
Depending on the scope of the client engagement, we may collect non-public customer data in the form of checklists, forms and applications, in written notations, and in documentation provided to us by our clients to help them meet their personal financial goals, while guarding against any real or perceived infringements of their rights or privacy. We use this information for evaluation, registration, licensing or related consulting services. We also create electronic records and internal lists of such data.
During regular business hours, access to customer records is monitored so that only those with approval may access the files. During hours in which the company is not in operation, the customer records are secured and locked. The firm maintains a secure office and computer environment at all times to ensure that client information is safe.
No individual who is not so authorized shall obtain or seek to obtain personal and financial customer information. No individual with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of a firm principal. Failure to observe BCJ procedures regarding client and consumer privacy will result in discipline and may lead to termination.
Sharing Nonpublic Personal and Financial Information
BCJ is committed to the protection and privacy of its clients’ and consumers’ personal and financial information. BCJ will not share such information with any affiliated or nonaffiliated third party except:
- When necessary to complete a transaction in a client account, such as with the clearing firm or account custodians;
- When required to maintain or service a client account;
- To resolve client disputes or inquiries;
- With persons acting in a fiduciary or representative capacity on behalf of the client;
- With rating agencies, persons assessing compliance with industry standards, entities with compliance oversight, or to the attorneys, accountants and auditors of the firm;
- To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
- To comply with federal, state or local laws, rules and other applicable legal requirements;
- In connection with a written agreement to provide investment management or advisory services when the information is released for the sole
purpose of providing the products or services covered by the agreement;
- In any circumstances with the client’s instruction or consent; or
- Pursuant to any other exceptions enumerated in the California Information Privacy Act.
** For unaffiliated third parties that require access to client personal information, including financial services companies, consultants and auditors, BCJ also requires the strictest confidentiality in its agreements with them. Federal and state regulators may also review these records as permitted by law.
It is not a policy of BCJ to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service client accounts or is mandated by law, there are no allowances made for clients to opt out.
Personal identifiable information about our clients is maintained during the time they are a client, and for the required time thereafter that is required by law. After this time, all such information will be carefully destroyed.