In November 1999, Congress passed major changes to modernize the laws that govern the financial services industry, including those designed to safeguard individual Privacy. Protecting our clients’ Privacy is of paramount importance and we recognize that financial matters are extremely private and sensitive in nature.
At LCG, we collect only the information that is required to provide our clients with the highest quality professional services or that is required by law and regulation. This nonpublic private information about our clients is collected from any number of the following sources: information we receive from them on applications or other forms; information about their business or personal transactions, our affiliates, or other third party sources.
Employee access to customer information is restricted to those who have a legitimate need to know in order to provide you with our professional services, or to comply with laws and regulations. We maintain both physical and electronic safeguards in accordance with federal law and regulatory standards. Any employee who has access to sensitive or private information receives training and is required to follow company procedures designed specifically to keep that information confidential.
Protecting your Privacy is an ongoing process. As technology continues to advance, LCG will continue to evaluate its security standards and procedures in order to protect our clients’ information with the best available means. Nothing is more important to us than our clients’ trust and confidence, and we will do whatever it takes to maintain the security of our professional relationships.
For purposes of this policy, the terms “Consumer”, “Client” and “Confidential Information” have the following definitions:
- The “Consumer” is not necessarily a client but may be anyone who is interested in the financial products or services offered by any of the affiliated entities within LCG Advisors. Examples of consumer relationships include: (a) a prospect with whom PCG is actively pursuing an investment management relationship; or (b) a prospect who provides PCG with nonpublic information on outside accounts (such as net worth information or potential portfolio size); or (c) executives who provide corporate information to Transaction Advisory Services or Capital Advisors.
- The “Client” means (a) an individual or company with a specific and continuous relationship with LCG who obtains or has paid LCG a fee for services that it has received or will receive.
- “Confidential Information” includes all confidential, proprietary and/or non-public information provided to LCG by a consumer or client. This includes, but is not limited to, information regarding social security numbers, assets, liabilities, income, net-worth, account balances, account numbers, bank account information, beneficiary information and investment activity (such as purchase and redemption history). For individuals, confidential information is synonymous with non-public personal information or “NPI.”
Protection of Material Nonpublic Information
Within LCG, certain affiliated lines of business maintain arrangements with third parties to perform various customer services. While all LCG employees may not be directly involved in the management of these activities, they are expected to not divulge information regarding our clients’ private information to any individual outside of the Firm, except:
- As necessary to complete transactions or account changes (for example, communications with portfolio management systems, attorneys or custodians);
- As necessary to maintain or service a client or his/her account (for example, approved communications with a client’s accountant);
- With various service providers providing administrative functions for LCG (such as a technology service provider), and only after LCG has entered into a contractual agreement (non-disclosure agreement) that prohibits the service provider from disclosing or using confidential information except as necessary to carry out its assigned responsibilities – and only for that purpose;
- With appropriate regulatory agencies; or
- As permitted by law
Collection and Dissemination of Personal Information
LCG may receive and maintain information such as user name, email address, telephone number and other personal information when such information is personally submitted by users through an account specific forms. The information provided may allow LCG to make specific inquiries or requests of the consumer or client or provide LCG with feedback on its services.
LCG’s headquarters, located in downtown Tampa has security officers on-site 24 hours a day, seven days a week. Video surveillance is deployed, and electronic access is restricted during off-hours, throughout the building. Generally, Confidential Information is stored electronically. In certain circumstance, physical information may be utilized in the course of an employee’s normal work activities. In such instances, the hard copy information is either (1) immediately disposed of through the use of a secure document disposal service with a bonded company or, (2) maintained under lock and key in the respective employee’s office.
Our technology systems are safeguarded for unauthorized activity or tampering through the use of restricted access sites, password protected information, and enhanced firewall and anti-virus technology. LCG utilizes the industry’s largest cloud-delivery security platform programmed to eradicate potential attacks that use malware, botnets and phishing. Additionally, LCG utilizes encryption for data that is “at-rest” and employs professional data security audits.
Employee access to specific client information is based on the need to support client activities either (a) within the unit directly responsible for the client activity or, (b) as an affiliated entity in support of the client activity. Strict controls limit employee access to different areas within the system and email monitoring is utilized for regulatory and compliance purposes in order to protect our clients’ information from potential misuse.
Privacy policies and procedures, together with security-awareness training helps to emphasize the importance of preserving client information. Newly hired associates receive an employee handbook and training that provides comprehensive information about, among other things, the firm’s policies and procedures related to the protection of client information.
Additional information about LCG Private Client Group is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for PCG is 170563.