Privacy Policy
The privacy policy statement is given to clients at the initial signing of the client contract and mailed or emailed with client consent once annually if the policy is updated. The CCO will document the date the privacy policy was delivered to each client for each year if an annual delivery is required. Great Lakes Inv Mgmt collects non-public personal information about clients from the following sources:
- Information it receives from them on applications or other forms;
- Information about their transactions with Great Lakes Inv Mgmt or others; and
- Information it receives from a consumer reporting agency.
Below are the reasons for which Great Lakes Inv Mgmt may share a client’s personal information.
- For everyday business purposes – such as to process client transactions, maintain client account(s), respond to court orders and legal investigations, or report to credit bureaus;
- For marketing by Great Lakes Inv Mgmt – to offer Great Lakes Inv Mgmt’s products and services to clients.
If a client decides to close his or her account(s) or becomes an inactive customer, Great Lakes Inv Mgmt will adhere to the privacy policies and practices as described in this Policies and Procedures Manual, as updated.
Great Lakes Inv Mgmt restricts access to clients’ personal and account information to those employees who need to know that information to provide products or services to its clients. Great Lakes Inv Mgmt maintains physical, electronic, and procedural safeguards to guard clients’ non-public personal information.
In addition to Great Lakes Inv Mgmt’s listed access persons, any IT persons or other technical consultants employed at the firm may also have access to non-public client information at any time. An on-site or off-site server that stores client information, third-party software that generates statements or performance reports, or third-party client portals designed to store client files all hold the potential for a breach of non-public client information.
To mitigate a possible breach of private information, Great Lakes Inv Mgmt uses encryption software on all computers and carefully evaluates any third-party providers, employees, and consultants with regard to their security protocols, privacy policies, and/or security and privacy training.
The system is tested and monitored at least annually.
The test conducted by the CCO will include the following activities:
- Attempt to access a random sample of firm devices to ensure that proper passwords are in place to prevent access;
- Attempt to access users’ accounts with the proper password to ensure that two-factor authentication prevents system access; and
- Attempt to restore a sample of files and records to ensure that the restoration process is sufficient and properly configured.
The results from the annual test will be documented and utilized as an opportunity to update the Information Security Policy
