Vorpahl Wing will not share the personal information of any client to any person or entity who is not party to the completion of a transaction or service offered. Vorpahl Wing shall not sell personal client information to any party.
Personal financial information about a client may be provided to a broker/dealer, custodian, mail service or other entity that is under contract with Vorpahl Wing to maintain or service client accounts. Vorpahl Wing shall require a privacy provision in each contract or agreement with any such provider which ensures confidentiality.
Additionally, Vorpahl Wing will restrict access to clients’ non-personal financial information to associated persons who need to know such information in order to provide products or services to clients.
Vorpahl Wing will maintain physical, electronic, and procedural safeguards that comply with federal standards to guard each clients’ personal financial information. Such safeguards include restricting the use of any information contained on the Client New Account Form to the client, the client’s personal representative, the Vorpahl Wing representative, Vorpahl Wing’s supervisory staff, or such other person(s) as the Chief Compliance Officer deems as needing to know the information. Vorpahl Wing staff should be especially cautious with the use of wireless fidelity (“Wi-Fi”) and not transmit or receive confidential company or client information from such a location without proper safeguards, such as may not be installed on personally owned computers.
Vorpahl Wing staff are required to adopt a “clean desk” policy in relation to personal information. When not being used by staff, documents containing personal information of clients are to be secured of stored in a manner which prevents them from being viewed by others. Staff is also required to exit from any internal computer programs containing personal information at the end of each business day. In addition, clients are prohibited from entering the cashiering area or any area where client and other confidential information is stored.
Hard copy of client personal financial information will be maintained in Vorpahl Wing’s central client files, and will be secured (locked) after normal business hours. Electronic access to client personal financial information will be restricted to the client’s representative and Vorpahl Wing handling the account. No client document containing personal information may be simply discarded. If such document is beyond retention schedule and President has authorized its removal for files, it must be properly shredded.
Should it be determined that there have been suspected or actual identity thefts, Vorpahl Wing shall promptly advise the client, work with the client, and notify the local FBI office.