Safeguarding Your Personal Information
Financial advisors are required by law to affiliate with a broker/dealer to process investment
transactions on your behalf, and your advisor has chosen Commonwealth Financial Network®
for this purpose.
Commonwealth, like all broker/dealers, is responsible for ensuring compliance with federal
and state regulations in a number of key areas—among them protecting investors' personal
and nonpublic financial information.
To that end, Commonwealth has implemented a Written Information Security Program
(WISP), which outlines specific policies and procedures for properly handling your
data and safeguarding it from misuse, unauthorized access or disclosure, loss, alteration,
or destruction.
This program complies with the strictest state and federal regulations currently in existence,
and its goal is to create a culture in which sensitive information is willingly and enthusiastically
protected. We believe that the administrative, physical, and technical safeguards that have been
implemented are appropriate to the size and complexity of our operation and the nature and
scope of our activities.
Compliance with federal regulations
Commonwealth's policies and procedures are in accordance
with SEC Regulation S-P, which implements certain provisions
of the Gramm-Leach-Bliley Act and the Fair Credit Reporting Act and
became effective on November 13, 2000. These policies and procedures
address administrative, technical, and physical safeguards for protecting customer records and
information and for responding to unauthorized access to or use of personal information. And,
as required, they are "reasonably designed to insure the security and confidentiality of customer
records/information, protect against anticipated threats to sensitive customer information,
and protect against unauthorized access to or use of customer records/information."
Proactively aiming for the highest standard
In addition to complying with federal regulations, Commonwealth must adhere to individual
state laws in every state where our advisors do business and where their clients reside.
While the states vary in the stringency of their laws, Commonwealth, in the best interest of
our advisors' clients, adopted the most rigorous standards across the breadth of our network.
Our program mandates myriad physical, technical, and administrative protections, and
compliance with them is required of all advisors, advisor support staff, and Commonwealth
home office employees. These measures include, but are not limited to:
- Physical safeguards. These include auto-locking doors and maintaining
controlled keycard access to Commonwealth facilities, providing for
the secure destruction and disposal of paper and media containing
personal information, and procedures for identifying and managing
visitors to Commonwealth facilities.
- Technology safeguards. In addition to the continuous monitoring of our home office systems
and data centers for threats, Commonwealth policies require up-to-date antivirus and spyware
protection on all computers, multiple layers of firewall protection, e-mail data encryption,
encryption of laptops and portable media, data-loss prevention, secure and environmentally
safe disposal of retired computer equipment, and the required, frequent resetting of strong
network passwords.
- Organizational safeguards. Through ongoing training and awareness programs on security
and privacy, we aim to ensure that home office employees understand the importance of
and means by which they must protect customer personal information, as well as the privacy
policies and standards that govern how Commonwealth handles personal information.
- Restricted access. Commonwealth authorizes access to your nonpublic personal information
only to Commonwealth employees and other third parties who need that information to serve
you or to assist us in conducting our operations.
- Auditing. Commonwealth performs internal home office and third-party audits of our
information security program in an effort to ensure that our program remains effective and
that safeguards designed to protect customer information are in place and adhered to.
An active and ongoing program
Commonwealth is firmly committed to complying with all laws and regulations designed
to protect the information entrusted to us. We continue to monitor changes to data security
regulations at both the federal and state levels, and we will amend our policies as necessary.
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