POLICY REGARDING SAFEGUARDING CLIENT INFORMATION
Cramer Rosenthal McGlynn, LLC (“CRM”) understands that our clients want their information to be kept private, and our goal is to properly safeguard their information. As such, we have adopted the following policy regarding safeguarding client information.
Client information is contained in electronic or hard copy form. CRM believes that the safeguarding procedures listed below are reasonably designed to provide a safe retention of client information.
Our primary repository for client information is an electronic database maintained at CRM. All systems that contain important client information are password protected. All systems containing client specific information have unique employee user levels. This allows CRM to grant access to client information to only those individuals who need it to perform services on behalf of the account.
We have instituted website privacy controls. For example, each client is issued its own individual username and password. Also, CRM’s systems have a firewall and antivirus software that protect our system from outsiders.
We seek to ensure that our third party vendors, which have access to client information in the ordinary course of business, have taken steps to protect client information and will not disclose such information to others.
Hard Copy Information
Client statements are maintained in a locked file room located in our New York office. This office is locked and access is controlled. Our facilities are secured with video monitoring equipment at each entrance. All doors to our offices are protected with electronic access cards issued to each employee.
CRM retains information for a minimum of seven years, and at times, ships information to a third party external storage. Our vendor performs all pick-ups and drop-offs with their trucks in order to properly safeguard our packages. Any stale or unnecessary client information is destroyed.
CRM requests permission from clients before using any clients’ name in any marketing literature. For further information, please contact our legal and compliance department.