ADV (Parts I and II)
Eagle Ridge Investment Management, LLC
Regulation S-P (“Reg S-P”) requires registered investment advisors to adopt and implement policies and procedures that are reasonably designed to protect the confidentiality of nonpublic personal records. The firm is committed to protecting the confidentiality of all information of all clients, prospective clients and former clients.
Although these procedures apply specifically to Nonpublic Personal Information, employees must be careful to protect all of the firm’s proprietary information.
Personal Information Collected
Eagle Ridge collects personal information about its clients to evaluate their financial needs, manage their accounts, provide individualized investment advice, or an overall financial plan. The personal information obtained includes:
- information provided on applications and other forms (such as name, contact information, social security number or occupation) and any additional information communicated to the company about clients’ personal and financial circumstances (family members, health status, assets or income);
- information about clients’ investments and transactions such as custodial statements and trade confirmations;
- information obtained from clients in connection with providing financial services such as correspondence, emails and notes from conversations or meetings.
Personal Information Protection
Employees are required to maintain the confidentiality of information acquired in connection with their employment, with particular care being taken regarding nonpublic personal information. Employees are educated on keeping client information secure, when joining the company and at least annually. This training continues to evolve as threats have increased, especially in the cyber area. Improper use of the Firm’s proprietary information, including personal information, is cause for disciplinary action, up to and including termination of employment for cause and referral to appropriate civil and criminal legal authorities. Nonpublic Personal Information is restricted to employees who have a need to know such information. Additionally, the company follows due diligence regarding third party selection and contract terms. The firm generally selects third parties who are well recognized within the industry and vetted by the firm’s Partners. Third parties only have access to client information on a need-to-know basis.
To comply with applicable laws and regulations, Eagle Ridge maintains physical, electronic, and procedural safeguards to protect this information. The details of these safeguards are in the Eagle Ridge Compliance Manual. Eagle Ridge also employs Information Technology consultants who help protect and maintain the firm’s network and software systems.
Personal Information Disclosure
Eagle Ridge may share the personal information described above for business purposes with the following companies not affiliated with us:
- Financial Service Providers – such as banks and brokers that provide custody and trade execution necessary to manage clients’ portfolios;
- Professionals – such as accountants, lawyers, actuaries and trust officers who may be involved in providing ancillary financial services provided clients request or consent to the dissemination of this information;
- Data Service Providers – such as third party technology consultants, the portfolio management system, planning software and the client relationship management software;
- Regulatory Authorities – as required by law;
- Others – as directed by the client.
Outside Business Activity
All personnel of Eagle Ridge must notify the firm and file an Outside Business Activity form before engaging in any business activity unrelated to Eagle Ridge. The form is available in Appendix VIII of the Compliance Manual.
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