Parametric Portfolio Associates® LLC (“Parametric”) considers client privacy to be a paramount obligation to its clients. Parametric is committed to maintaining the confidentiality, integrity and security of its current, prospective and former clients’ personal information.
As a matter of policy and practice, Parametric does not disclose client personal information (“Client PI”) externally, except as required or permitted by law. For the purposes of this policy, Client PI includes, but is not limited to client names, addresses, phone numbers, social security numbers or tax identification numbers, and bank or custodial account numbers. Parametric takes the obligation to safeguard non-public Client PI seriously. All employees are periodically reminded that Client PI is to be protected by Parametric and kept confidential in accordance with its fiduciary and ethical duties. Parametric may engage third parties to provide various services on behalf of firm clients. Such services may require that Client PI be provided to the service provider. Parametric will not provide Client PI to a service provider unless they have entered into a Non-Disclosure Agreement with Parametric or are otherwise contractually obligated to protect and safeguard client information.
PROCEDURES AND CONTROLS
Parametric has implemented the following procedures which are designed to ensure that the policy is communicated to clients, access to Client PI is restricted to appropriate personnel, and Client PI is safely secured and protected.
- Parametric’s Privacy Notice, attached hereto as Exhibit A, is to be distributed to new clients in accordance with Regulation S-P and CFTC Regulation 160.
- Parametric will provide the firm’s Privacy Notice to all existing clients if its policies and procedures with respect to the disclosure of Client PI to non-affiliated third parties are materially amended or as required by applicable law.
- Parametric will deliver its Privacy Notice to all existing clients on an annual basis if the firm discloses Client PI to any non-affiliated third parties other than in connection with the provision of services to clients.
- Client PI should not be left out in workstations, offices, or common areas (i.e., conference rooms) when not in use.
- Employees should retain Client PI in file cabinets or desk drawers when not being used.
- All Client PI should be properly stored at the end of the workday (i.e., in locked file cabinets and desk drawers whenever possible).
- Client PI and documentation that is deemed extraneous or redundant should be shredded and not merely recycled.
- Personnel must ensure that their visitors check in at the front desk and/or are accompanied at all times by firm personnel.
- Access to the Company’s office space during and after business hours requires the use of a key card.
- All employees are bound by the Company’s Code of Ethics which obligates them to keep Client PI confidential.
- Access to Client PI is restricted to those employees who need such information to provide services to such client.
- All email sent externally which contain Client PI or data should be encrypted. Email attachments which contain Client PI should be password protected. Passwords should be provided to the recipient in a separate email or via telephone.
- Prior to divulging Client PI externally, an employee should reasonably verify that the recipient is the client, a properly authorized fiduciary representative of such client, or a party that needs the information to complete a service or transaction pursuant to the client agreement (i.e., a broker-dealer, custodian, fund administrator or transfer agent).
Parametric has established various policies, controls and electronic safeguards to protect the firm, its employees and its clients. These safeguards are detailed in the firm’s Acceptable Use Policy and other related policies. These policies, controls and safeguards are designed to protect confidential information, including Client PI, that is maintained on the firm’s servers, workstations and laptops, mobile devices and applications.
BREACH OF INFORMATION PROCEDURES
In the event Client PI is transmitted to an unintended recipient or Client PI is otherwise breached, it should be promptly reported to Parametric’s Chief Compliance Officer (“CCO”). The CCO or his or her designee will evaluate the breach and ensure that appropriate corrective actions are taken, which include but are not limited to: notifying the affected client(s), reporting the client privacy breach to applicable regulatory authorities, contacting the unintended recipient, and consulting with business groups to help prevent the future recurrence of a breach. All breaches of Client PI will be logged by Compliance.
Parametric Portfolio Associates® LLC (Parametric) considers client privacy to be a fundamental aspect of its relationship with clients and is committed to safeguarding all client-related personal information as defined under the privacy rules published under Section 504 of the Gramm-Leach-Bliley Act, as amended. Parametric does not disclose non-public personal information concerning its clients, former clients, or investors in certain limited partnerships over which the firm acts as a general partner, to any other party or person except as permitted and/or required by law, an applicable regulatory authority, or as outlined below.
Parametric may, in limited circumstances, have the need to collect non-public personal information about its clients and investors in certain limited partnerships over which the firm acts as a general partner. This information may include but is not limited to:
- Name, address, telephone number, and tax identification number.
- Government issued identification such as a driver’s license or passport.
- Assets, income, bank and investment accounts, credit information, custodian, IRS tax status or other financial or investment related information.
- Applications, subscriptions, suitability and similar forms or questionnaires.
- Legal documents such as trust agreements, financials, and ownership records.
Parametric may collect personal information when an individual account is opened or when the information is provided by that client’s advisor. This material may be accumulated from sources such as account applications and related documents; other written, electronic or verbal correspondence; transactions; a brokerage or financial advisory firm, financial adviser or consultant; and/or information captured on Parametric’s internet web site. Parametric retains the personal information of current and former clients in accordance with Rule 204-2 of the Investment Advisers Act of 1940.
Parametric may share client information with its affiliates or subsidiaries as needed to conduct business. From time to time, Parametric may engage the services of third-party vendors or consultants to assist with the management of client portfolios. In that respect, information will be provided on a need-to-know basis only and the external parties will agree to hold all such information confidential. Parametric may also disclose or share information, to the extent permitted by law, with other financial institutions with which Parametric and/or its clients have a joint business arrangement in managing and/or servicing the client.
Parametric’s procedures are designed to restrict access to non-public personal information to appropriate personnel. Parametric maintains physical, electronic and procedural safeguards that comply with federal standards to safeguard current and past client related personal information.
Parametric does not sell non-public personal information to any external source and does not distribute this information to unrelated third-party providers unless necessary for business related purposes in connection with the servicing and management of client assets. Parametric cannot, however, guarantee clients against information theft which is beyond its reasonable technological abilities and controls.
Clients are provided with Parametric’s Privacy Notice at the time their account is incepted. Parametric reserves the right to periodically review and revise its Privacy Notice and will provide updates when materially amended or as required by applicable law. At all times, a client may notify Parametric in writing to restrict all non-public personal information from being distributed (except to regulators and/or by law) to any external parties including affiliates, consultants, and client-related financial advisors. Clients are forewarned, however, that doing so may severely inhibit Parametric’s ability to properly manage the client’s assets and/or appropriately conduct business on behalf of the client. Please direct any questions or concerns to Parametric Compliance at 800 5th Avenue, Suite 2800, Seattle, WA 98104, or 206-694-5575.