As with any business, we have our own accounting and bookkeeping, insurance and other service firms that we may need to provide information that is considered nonpublic personal information. An example might be your account activity for our financial statements, which might be for internal or external purposes. Another example would be computer consultants that must have access to certain client records so as to be able to increase the efficiency of our computer processing systems. We have always insisted that any such information that needed to be disclosed for a business purpose be considered confidential and not used for any purpose other than the specific business need. That well-understood business policy of confidentiality will be reinforced as needed by contractual agreements between such service providers to the firm, referencing the Federal Trade Commission (FTC) regulations.
Other than as stated above, we do not disclose nonpublic personal information, or any other information, to any outside party without specific client authorization. An example would be other professionals who are assisting the firm in carrying out a client engagement. In such a case, we would require the client’s approval for such a disclosure.
In addition to the privacy protection that the new FTC regulations provide you, the Internal Revenue Code prevents the disclosure of client information provided for tax planning or preparation services without the client’s written permission. Further, the ethics rules that govern the operation principles that our firm must follow prohibit disclosing client information.