As former executives, we understand the need for confidentiality and sensitivity better than most. For this reason, we have made a formal commitment to confidentiality which is embedded into our Code of Practice.
Under our “Principles of Confidentiality”, we have strict policies to ensure that client confidentiality is protected at all times. We train all our team members to apply our Code of Practice, which they sign up to on joining our team. We guarantee the highest standards of business ethics at all times.
In addition to signing confidentiality agreements with our clients, we also ensure that all our team members have agreed to provide services under the following separate non-disclosure statement.
It is the policy of Squiggle.me and Squiggle Group companies and affiliates (herein individually and collectively called “Squiggle”) that users (i.e., employees, consultants, students, volunteers, contractors, vendors, outside affiliatesand any others who are permitted access to Squiggle systems and/or Squiggle information) shall respect and preserve the privacy, confidentiality and security of confidential information (“CI”) which shall include: (1) individually identifiable client information in any format, including, but not limited to paper and electronic estate planning documents and/or any other documents relevant to the preparation of a client’s estate, such as bank statements, HMRC and tax documentation, medical records, property deeds, investment documentation, security information in relation to the completion of money laundering and credit searches, social media and other online accounts, etc). (2) personnel information (e.g., disciplinary or other information about employees, volunteers, students, contractors, affiliates), (3) confidential business information of Squiggle and/or third parties, including third-party software and licensed products or processes, or (4) other non-public information, or research (such as academic information and reports, survey results and related presentations). Confidential information may be created internally or received from other institutions, and may be in any format including paper, verbal/oral communication, audio recordings or electronic format. I understand and agree that I will only access, maintain, use or disclose confidential information for legitimate job-related, need-to-know purposes.
I further agree that:
- I will protect the privacy, confidentiality and security of Squiggle client information at all times.
- This is in accordance with the laws of England and Wales and applicable Squiggle Group policies and procedures.
- I will complete all required information privacy and security training required by Squiggle policies and procedures.
- I will not maintain confidential information on any unencrypted portable computing device (laptop, smartphone, tablet etc.) and I will not electronically transmit confidential information in an insecure manner.
- I will not disclose my username and/or password for any Squiggle system, application or device to which I have access; I will not use another person’s username and password to access confidential information on any Squiggle electronic system, and I will not leave any system, application, or computer containing confidential information unattended while I am signing on.
- I will not attempt to access any confidential information in electronic format on any Squiggle system, application or device, or access a restricted physical area containing confidential information without proper authorisation or for purposes other than official Squiggle business.
- I will only alter or destroy confidential information in accordance with applicable Squiggle policies and procedures.
- I will immediately report to my supervisor (or the appropriate Squiggle Group office) any known or suspected incident involving the unauthorised access, use or disclosure of confidential information, and I will fully cooperate in any resulting investigation and make myself available for all related interviews and provide all relevant information requested during such investigation.
- I will safeguard from loss, theft or unauthorised use/access Squiggle-owned equipment/property on which confidential information is stored or through which confidential information may be accessed. I will immediately notify the Squiggle Information Security Team if any portable computing device I use to store or access confidential information is lost or stolen.
- I will not store or transmit confidential information on my personal equipment/property (such as personallyowned computing devices) unless permitted by and in accordance with applicable Squiggle policies or procedures.
- I will abide by Squiggle social media policies at all times and I will never post client identifiable information on social media in violation of Squiggle policy.
- I will not take photographs, make videos or make other recordings of clients, staff or visitors, except in accordance with applicable Squiggle policies and procedures.
- I understand that my access to confidential information on Squiggle electronic systems and my Squiggle email account may be audited.
- I will not access or obtain my own, my friend’s or a family member’s estate planning information maintained by Squiggle without appropriate written authorisation and under applicable Squiggle policies and procedures.
I agree that I have read, understood and will comply with the terms of this Confidentiality Statement. I understand that my failure to comply with this Confidentiality Statement may result in termination of access to Squiggle electronic estate planning documentation, and may lead to disciplinary action, including civil or criminal legal penalties (up to and including termination of employment, contract, or partnership agreement), or loss of Squiggle privileges or contractual or affiliation rights. AFTER MY EMPLOYMENT OR CONTRACTUAL ENGAGEMENT ENDS, I WILL NOT TAKE ANY CONFIDENTIAL INFORMATION WITH ME AND I WILL NOT FURTHER USE OR DISCLOSE ANY CONFIDENTIAL INFORMATION.
Examples of Breaches of Confidentiality
Accessing confidential information that is not considered to be within the scope of your duties:
- Unauthorised access or reading of client estate or account information.
- Unauthorised access of personnel file information.
- Accessing information for which you do not have a legitimate job-related “need-to- know” purpose for the proper execution of your duties.
Misusing, disclosing without proper authorisation, or altering confidential information.
- Making unauthorised entries into a client’s record.
Making unauthorised changes to a personnel file.
Sharing or reproducing information in a clientrecord or a personnel file with unauthorized personnel.
- Discussing confidential information in a public area such as a waiting room or elevator.
Disclosing to another person your sign-on code and password for accessing electronic confidential information or for physical access to restricted areas:
- Telling a co-worker your password so that he or she can log into your work or access your work area.
- Telling an unauthorised person the access codes for personnel files, client accounts, or restricted areas.
- Posting passwords and sign-on codes in a location where they may be viewed by others.
Using another person’s sign-on code and/or password for accessing electronic confidential information or for physical access to restricted areas:
- Using a co-worker’s password to log into the Squiggle computer system or access their work area.
- Unauthorised use of a login code for access to personnel files, client accounts, or restricted areas.
Intentional or negligent mishandling or destruction of confidential information:
- Leaving confidential information in areas outside of your work area, such as the cafeteria or your home.
- Disposing of confidential information in a non- approved container, such as a rubbish bin.
- Failure to promptly report the loss or theft of Squiggle-owned equipment/property assigned to you or the misuse of this equipment/property.
- Failure to report the loss or theft of personallyowned equipment containing UNC Health Care confidential information.
Leaving a secured application unattended while signed on:
- Being away from your desk while you are logged into an application.
- Allowing a co-worker to use your secured application for which he or she does not have access after you have logged in.
- Taking or allowing photographs to be taken of clients or client information without obtaining the required authorization.
- Posting photos or confidential information on social medial or public access point.
Attempting to access a secured application or restricted area without proper authorisation or for purposes other than official Squiggle business.
- Trying passwords and login codes to gain access to an unauthorized area of the computer system or restricted area.
- Using a co-worker’s application for which you do not have access after he or she is logged in.
These examples are only a few examples of mishandling confidential information. If you have any questions about the handling, use or disclosure of confidential information, please contact your supervisor, manager, or director.