As a registered investment adviser, Light Financial Services Inc must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisors to adopt policies and procedures to protect the "nonpublic person information" of natural person consumers and customer and to disclose to such persons policies and procedures for protecting that information. Nonpublic personal information includes nonpublic "peronally identifiable financial information" plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed or transactions entered into on behalf of clients, advice provided by Light Financial Services, Ine to clients, and data or analyses derived from such nonpublic personal information. Light Financial Serivces Inc must also comply with the California Financial Information Privacy Act (SB1) if the firm does business with California consumers.
The purpose of these privacy policies and procedures is to provide administrative, technical and physical safeguards which assist employees in maintaining the confidentiality of nonpublic personal information collected from the consumers and custoemr of an investment advisor. All nonpublic information, whether relating to an advisor's current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.
Paul A Light is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Light Financial Services Inc's client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. Paul A Light may recommend to the President any disciplinary or other action as appropriate. Paul A Light is also responsible for distributing these policies and procedures to employees and conducting appropriate employee training to ensure employees adherence to these policies and procedures.
Light Financial Services Inc has adopted various procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:
Light Financial Services Inc maintains safeguards to comply with federal and state standards to guard each client's nonpublic personal information. Light Financial Services Inc does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:
Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside of Light Financial Services Inc, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client.
Light Financial Services Inc restricts access to nonpublic information to those employees who need to know such information to provide services to our clients.
Any employee who is authorized to have access to nonpublic personal information is required to keep such information in a secure compartments or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving nonpublic information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.
Safeguarding standards encompass all aspects of the Light Financial Services Inc that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that Light Financial Services Inc may adopt include:
Some methods of disposal to ensure the information cannot practicably be read or reconstructed that Light Financial Services Inc may adopt include: