One of our most important assets is the information that we generate in the course of business. Any information you encounter while working in the course of your employment is the property of Insurance Services. Improper disclosure can create serious financial or competitive losses or disadvantages to the Company, and legal liabilities to the Company and individual employees.

When handling financial and personal information about policy holders or others (e.g., employees, business partners, etc.) with whom Insurance Services has dealings, observe the following principles:

• Collect, use, and retain only the personal information necessary for your job function.
• Retain information only for as long as necessary or as required by law or our record retention policy.
• Limit internal access to personal information to those employees who have a legitimate business reason for seeking that information.

You should exercise caution when discussing company business where conversations can be overheard such as in the hallway or at a restaurant. Care must be taken not to leave confidential information in open areas such as photocopiers or the fax machine. Even obsolete or prior versions of Company confidential information must be properly safeguarded.

You are obligated to keep information you obtained during your employment confidential, even after you leave. Employees leaving Insurance Services must safeguard and return confidential information in their possession.