- Interactive Computer Corporation (“ICC”) acting on behalf of, and at the direction of
its clients, processes, prepares, stores and disseminates financial documents which
may contain “Nonpublic Personal Information.” The transmission or conveyance of
said documents, whether by public or private carrier or electronic means is at the
sole discretion and direction of ICC’s client.
- Acting as a service provider, ICC is committed to complying with the provisions of
Public Law 106-102 known as the Gramm-Leach-Bliley Act and the Federal Trade
Commission’s “Standards For Safeguarding Customer Information: Final Rule (16
CFR PARTS 313, 314).”
- ICC is committed to safeguarding any client information that it accesses, prepares or
disseminates according to commercially acceptable standards and no less rigorously
than it uses to protect its own confidential information.
- ICC is committed to maintaining data backups and such business interruption
(disaster planning and recovery) safeguards as are prudent for an organization of
ICC’s size.
- ICC is committed to providing notification of any breach or suspected breach of their
systems directly to the client.
- ICC has unilaterally amended all client agreements to incorporate the following provisions:
- A stipulation that any nonpublic personal information or any other information provided
by the client will be held in strict confidence and accessed only for the explicit
business purposes dictated by the client;
- A stipulation that ICC assets no right or title to ownership of client’s data. A further
expression of this statement can be found on our web site at http://
www.iccdocs.com under Privacy Disclosure.
- Provisions allowing for the return or destruction of all confidential information received
by ICC at the termination of the client relationship;
- A stipulation allowing for the entry of injunctive relief without posting a bond to
prevent or remedy a breach of the confidentiality obligations of the client agreement;
- A limited provision allowing the auditing of ICC’s compliance with privacy provisions
provided that there is no potential or actual disclosure of another client’s
information or processing requirements;
- ICC does not share data with any affiliated or independent third-party. ICC will
insure that all subcontractors, if any, will sign a confidentiality agreement consistent
with privacy legislation then in effect;
- A provision ensuring that the agreement’s protective requirements with respect to
information confidentiality shall survive the termination of the client relationship.
Reviewed: June, 2008 |