BMO Wealth Management U.S. is committed to protecting the confidentiality and integrity of the information to which it has been entrusted by its clients, as well as BMO Wealth Management U.S.'s proprietary information, including its products, the information systems and technology infrastructure, and the services it provides (collectively, “Information”). The Privacy and Information Security Policy (“Policy”) outlines the principles that govern all BMO Wealth Management U.S. business units and regulated direct or indirect subsidiaries of BMO Wealth Management U.S. (collectively, “BMO Wealth Management U.S.”) with respect to the collection, sharing, and protection of Information. BMO Wealth Management U.S. will adopt and implement procedures to achieve the Policy goals: to obtain, maintain and disseminate Information appropriately; to ensure the security and confidentiality of Information; and, protect against anticipated internal or external threats or hazards to the security or integrity of the Information.
Information takes many forms and includes records stored on computers and magnetic or optical media, data transmitted across networks or by fax, and information printed out or written on paper. It can also consist of work knowledge or concepts and can be represented in material objects. Specifically, BMO Wealth Management U.S. may obtain “Nonpublic Personal Information,” information about an individual obtained in connection with providing a financial product or service to the individual for personal, family or household purposes. Nonpublic Personal Information may include, but is not limited to, name, address, social security number, account number or balance, debit card usage, and insurance policy coverage and may be provided to BMO Wealth Management U.S. directly by the individual or obtained from transactions with BMO Wealth Management U.S. or others.
3. Use of Nonpublic Personal Information
BMO Wealth Management U.S. uses the Nonpublic Personal Information it collects in a variety of ways depending on the nature of the customer’s relationship including, but not limited to, delivering various financial services; processing, servicing and maintaining accounts and transactions; responding to customer requests; resolving disputes; and generally fulfilling BMO Wealth Management U.S.’s obligations to the customer. In addition, the information may be used to verify a customer’s identity as required by the USA PATRIOT Act.
4. Disclosure of Nonpublic Personal Information
BMO Wealth Management U.S. does not disclose any Nonpublic Personal Information to third parties, except as permitted or required by law, rules or regulations. BMO Wealth Management U.S. may disclose Nonpublic Personal Information to other financial institutions with which it has a joint marketing agreement or similar arrangement. Nonpublic Personal Information may be disclosed to affiliated and nonaffiliated third parties to enable them to provide business services for BMO Wealth Management U.S., including marketing services, for us, such as helping to evaluate requests for products or services, performing general administrative activities and/or assisting in processing transactions. The affiliated and nonaffiliated third parties are required to protect the confidentiality and security of this information and to use it only in accordance with BMO Wealth Management U.S.’s instructions. In the event that a customer decides to close an account or otherwise becomes an inactive customer, BMO Wealth Management U.S. will continue to follow its privacy and information security practices.
6. Vermont and California Residents Only
The information practices described above comply with federal law. Vermont and California laws place additional limits on sharing Nonpublic Personal Information about their residents. If a customer is a Vermont or California resident, BMO Wealth Management U.S. will automatically limit the disclosure of Nonpublic Personal Information to affiliated and nonaffiliated third parties as permitted or required by applicable law or regulation.
7. Information Security
BMO Wealth Management U.S. maintains physical, electronic and procedural safeguards to protect Information. BMO Wealth Management U.S. is committed to the following principles to ensure the confidentiality and protection of Information: maintaining Information security, taking into consideration business requirements, risk mitigation, industry practice, and legal and regulatory requirements; protecting all forms of Information; implementing security measures that are effective, consistent and cost justified; effective implementation by management and staff for adherence to policies and procedures; monitoring advances in security technology to ensure that BMO Wealth Management U.S. is providing an appropriate level of privacy and safety; and, appropriate reporting of deviations from the policies and procedures or security breaches. BMO Wealth Management U.S. employees are required to protect the confidentiality of Information and observe policies and procedures in accordance with their job function. Employees may only access Information when there is an appropriate reason to do so, such as to administer or offer BMO Wealth Management U.S. products and services and may be subject to disciplinary rules for noncompliance with policies and procedures. BMO Wealth Management U.S. may conduct business in various locations where the laws conflict with BMO Wealth Management U.S.’s established policies and/or procedures. In such instances, BMO Wealth Management U.S. will make appropriate modifications to comply with local law.
8. Administrative Responsibilities
Several individuals are responsible for defining, maintaining and publishing the procedures necessary to implement the privacy and information security principles, including without limitation BMO Wealth Management U.S.. BMO Wealth Management U.S. will oversee the coordination of privacy and information security activities within the organization and review the activities from a business and regulatory perspective. BMO Wealth Management U.S. will review the Policy at least annually.