Brown Capital Management is committed to the confidentiality and privacy of our clients' non-public personal information. This commitment extends to all clients with whom Brown Capital Management has a relationship, including former clients.
Categories of Information
Brown Capital Management comes into possession of and/or collects non-public personal information about our clients (the "Information"):
- from applications, correspondence, account contracts, fiduciary documents and other documents and forms;
- from client transactions with us, account activity and holdings; and,
- from third parties from which clients have authorized us to obtain Information.
Disclosures to Third Parties
Brown Capital Management does not disclose Information about our clients or former clients to third parties except as permitted by law. Third party processors or service providers may have access to Information of clients in order to provide or assist Brown Capital Management in providing services to Brown Capital Management clients. In all cases, such third parties are prohibited from using, disclosing or releasing Information outside the scope of providing such services and have executed contracts containing confidentiality provisions.
In the event that Brown Capital Management intends to disclose Information to a third party that is not providing services to Brown Capital Management, Brown Capital Management will notify all affected clients of such intended disclosure. Each such client will be advised of the nature of the disclosure and given instructions on how to opt out. At present, Brown Capital Management has no intention of disclosing Information to third parties beyond the necessary disclosures to processors and service providers and as otherwise permitted by law.
Brown Capital Management restricts access to Information about clients to those employees who need to know that Information to provide services to such clients. Brown Capital Management maintains physical, electronic and procedural safeguards that comply with state and federal regulations to guard client Information. The Company's independent auditor examines the control objectives established by the Company related to Investment Management, Trust and Custody services and performs testing to determine whether those controls tested were operating with sufficient effectiveness to provide reasonable assurance that the control objectives were achieved.