October 1, 2008

C.H. Nickerson & Co. values our employees’ privacy and has taken the following steps to ensure that your personal information is not available to unauthorized persons:

1. Personal information such as social security numbers, drivers’ license numbers, bank account numbers and credit or debit card numbers and health insurance identification numbers is confidential information and must be recognized as such.  No employee has the authority to release such information to anyone without written permission.  In addition, this information may not be accessed without a legitimate business need.
2. All employees whose job gives them access to this information, will be notified that such information must be treated as confidential and such employees shall take all necessary steps to protect the confidentiality of this information.
3. Any written document which contains personal information such as social security numbers and other personal information described above shall be kept in a locked and secure place, and access to such documents shall be limited to employees with a business need to use such information for work related purposes.
4. Any such personal information shall be reasonably protected by limiting access to such information to employees with a legitimate business need to use such information for a work related purpose.  Such information that is stored on computers shall be password protected and in addition protected by limiting access to those with a business need to use such information.
5. Personal information such as social security numbers, bank account numbers, credit card and debit card numbers etc., shall be deleted from any document or computer file prior to the disposal of the document or the computer file.
   

Any individual who learns that personal information is being mishandled shall report such misuse to executive management or their supervisor.