In Global Fund Services’ capacity as transfer agent and prospect services agent (services agent), we are mindful of our clients’ privacy obligations to their shareholders under Regulation S-P. Accordingly, pursuant to its transfer agency or investor recordkeeping agreements with its clients, Global Fund Services keeps all records and other information relative to investors confidential and will not use this information other than for purposes of fulfilling its transfer agent or investor recordkeeping duties, except when requested to divulge such information by duly constituted authorities or court process, or when requested by an investor or an investor’s agent.
In our role as services agent, we will collect the following Nonpublic Personal Information from current and prospective customers/shareholders:
- Information concerning identity such as name, address, date of birth and social security number;
- Information about current and historical financial transactions;
- Information on applications including beneficiary and bank information;
- Information received on other documents, through data transmissions, email, facsimile or by telephonic device which may include all the above Nonpublic Personal Information.
This information is collected by employees in their normal course of employment with U.S. Bank. All services agent 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 Regulation S-P and to prevent any unauthorized access or use of Nonpublic Personal Information maintained by it for its investment company clients:
- All employees must be fingerprinted.
- All employees must electronically sign a disclosure that they have read the U.S. Bank Code of Ethics and Business Conduct including the section on confidentiality.
- Maintain separate locked receptacles for shredding Nonpublic Personal Information that requires discarding.
- Segregate duties among services agent’s 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 services agent 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 or transport layer security to further protect a customer's Nonpublic Personal Information on the Internet.
- Provide ongoing training to all services agent’s employees to reinforce importance of confidentiality of customer/consumer Nonpublic Personal Information.
For privacy related information, please visit usbank.com/privacy. For California related privacy requests, please visit the U.S. Bank California Privacy Center or call our toll-free phone number 1-800-872-2657.