At U.S. Bank, trust has always been the foundation of our relationship with customers. Because you trust us with your financial and other personal information, we are committed to respect your privacy and safeguard that information. In order to preserve that trust, the U.S. Bank family of financial service providers pledges to protect your privacy by adhering to the practices described below.
Trust has always been the foundation of our relationship with customers and their shareholders. We are committed to respect your privacy and safeguard that information. In our capacity as transfer agent and prospect services agent will collect the following Nonpublic Personal Information from current and prospective customers/shareholders:
- Information concerning identity such as name, address and social security number;
- Information about current and historical financial transactions;
- Information on applications including beneficiary and income amounts;
- Information received on other documents, through data transmissions, email, facsimile machines or by telephonic device which may include all of the above Nonpublic Personal Information.
This information is collected by employees in their normal course of employment with U.S. Bank. All transfer agent and prospect services employees may have some type of access to Nonpublic Personal Information. Several managers and supervisors consistently and routinely monitor the activities of these employees.
We have adopted the following internal controls to ensure compliance with Reg. S-P and to prevent any unauthorized access or use of Nonpublic Personal Information maintained by it for it's investment company clients:
- All transfer agent and prospect services' employees must be Fingerprinted.
- All employees must sign a disclosure that they have read the U.S. Bank employee handbook including the section on confidentiality
- Maintaining separate locked receptacles for shredding Nonpublic Personal Information that requires discarding.
- Segregation of duties among transfer agent and prospect services' personnel including a quality control check of incoming and outgoing Nonpublic Personal Information.
- Verify authenticity of customer/shareholder by requiring customer to provide certain pieces of Nonpublic Personal Information to prevent unauthorized access to correct customer/shareholder's Nonpublic Personal Information.
- Provide quality control checks on transfer agent and prospect services personnel responsible for entering Nonpublic Personal Information of customers and consumers.
- Provide levels of system security through unique log on IDs and passwords to prevent access to Nonpublic Personal Information by unauthorized users
- Encrypt all electronic data transmissions containing Nonpublic Personal Information.
- Utilize secure socket layer security to further protect a customer's Nonpublic Personal Information on the Internet.
Provide ongoing training to all transfer agent and prospect services' employees to reinforce importance of confidentiality of customer/consumer Nonpublic Personal Information.