Lyons Wealth Management, LLC
Procedures to Safeguard Client Records and Non-Public Personal Information 03/27/2023
LWM shall strive to: (a) ensure the security and confidentiality of consumer, customer and former customer records and information; (b) protect against any anticipated threats or hazards to the security or integrity of consumer, customer and former customer records and information; and (c) protect against unauthorized access to or use of consumer or customer records or information that could result in substantial harm or inconvenience to any customer. Accordingly, the following procedures will be followed:
A. Confidentiality. Employees shall maintain the confidentiality of information acquired in connection with their employment with LWM, with particular care taken regarding Non-Public Personal Information. Employees shall not disclose Non-Public Personal Information, except to persons who have a bona-fide business need to know the information in order to serve the business purposes of LWM and/or Clients. LWM does not disclose, and no Employee may disclose, any Non-Public Personal Information about a Client or former Client other than in accordance with these procedures.
B. Information Systems. LWM has established and maintains its information systems, including hardware, software and network components and design, in order to protect and preserve Non-Public Personal Information.
Passwords and Access. Employees use passwords for computer access, as well as for access to specific programs and files. Non-Public Personal Information shall be maintained, to the extent possible, in computer files that are protected by means of a password system secured against unauthorized access.
Access to specific LWM databases and files shall be given only to Employees who have a bona-fide business need to access such information. Passwords shall be kept confidential and shall not be shared except as necessary to achieve such business purpose. User identifications and passwords shall not be: stored on computers without access controls, written down, or stored in locations where unauthorized persons may discover them. Passwords shall be changed if there is reason to believe the password has been compromised. All access and permissions for terminated Employees shall be removed from the network system promptly upon notification of the termination.
To avoid unauthorized access, Employees shall close out programs and shut-down their computers when they leave the office for an extended period of time and overnight. Terminals shall be shut-down when not in use during the day and laptops shall be secured when leaving LWM premises. Confidentiality shall be maintained when accessing the LWM network remotely through the implementation of appropriate firewalls and encrypted transmissions.
280 W. Canton Ave STE 430, Winter Park, FL, 32789
Phone: (407) 951-8710
www.LyonsWealth.com