Below are the reasons for which Great Lakes Inv Mgmt may share a client’s personal information.
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:
The results from the annual test will be documented and utilized as an opportunity to update the Information Security Policy