A fiduciary relationship is confidential in nature, and it is the policy of NTMS to disclose trust records only under the following conditions:
- The request for information is made by a party whose beneficial interest entitles them to such information under the law;
- The request for information is made by court order or subpoena, in writing;
- The request for information is made by federal, or state, or other regulatory authorities having an official interest in examination and supervision of the Company;
- The request for information is made by the directors, officers or staff of affiliate companies, or holding company, and is needed to properly serve our clients;
- It is determined by the President of NTMS that disclosure is in the best interests of the client(s).
NTMS has a policy not to disclose any trust records or customer information with non-affiliated third parties, with the exception of the service providers referenced at the end of the policy. Fiduciary personnel are expected to take reasonable steps to see that such information is not inadvertently disclosed.
NTMS may share information with companies that provide services (servicing arrangements) such as trust accounting functions, investment companies, data processing, recordkeeping, and statement mailing services. The companies providing these services act on our behalf and are obligated to keep the information that we provide to them confidential.
The Company, to the best of its ability, will protect any online information provided to or from individuals through the company’s internet site(s), or data sites used by the service providers of the Company.
Personnel are expected to protect the personal information of all employees, officers and directors. Any requests for such information must be made in writing, and referred to the President of the Company.
The Gramm-Leach-Bliley Act of 1999 (GLBA) specifies the requirements for notifying customers of privacy policies and practices. It is the policy of the Company to provide each customer with a privacy notice at the time the customer relationship is established and annually thereafter.
A “consumer” as it relates to privacy policies and practices is anyone who desires to or obtains from the Company any financial product or service that is to be used primarily for personal, family, or household purposes. A “customer” as it relates to privacy policies and practices is any consumer who has a continuing relationship with the Company for the purpose of obtaining a financial product or service. A “privacy notice” is a description of the privacy policies and practices of the Company, including policies with respect to the disclosure of nonpublic personal information to affiliates and nonaffiliated third parties.
According to regulatory guidelines, each agency, custody and IRA account customer is considered a “customer” for purposes of providing a privacy notice. The definition of customer does not include those accounts for which the Company acts as trustee.