As wholly owned subsidiaries of the Massachusetts Bankers Association, Massachusetts Financial Services Insurance Agency, Inc. and New England Financial Services Insurance Agency, Inc. value our relationship with you our client and are committed to responsible information handling practices. We are committed to the safekeeping of the non-public personal and confidential information that you may provide us in the course of our serving you and providing you with various insurance products and services as insurance agents or insurance brokers.

We are providing you with this notice so that you will understand how we use and protect your non-public personal and confidential information. Please read this notice and keep it for your records. By maintaining a customer relationship with us, you consent to our collection and use of your non-public personal and confidential information.

We limit the collection, use and retention of non-public personal and confidential information to what we believe is necessary to conduct our business, to provide you with quality service, to comply with federal, state and local regulations, and to make available to you other products and services that we offer to all of our clients.

We may collect non-public personal and confidential information about you from:

i. information that you provide us on application forms or in other underwriting information that we may ask you to provide during the process of acting as insurance agents or brokers in seeking quotes on your behalf for the various insurance products and services that we offer our clients including but not limited to federal tax identification numbers, bank accounts, subsidiary names and addresses, holding company names and addresses; names of officers and directors and outside directors business affiliations, resumes of newly hired officers and newly appointed directors, employees’ names, birthdates, social security numbers, medical, dental, life, disability or other insurance plan identification numbers, etc.;
ii. information that we obtain in order to service you including but not limited to telephone numbers, fax numbers, e-mail addresses, web site addresses, post office box numbers, street addresses, products and services that you currently offer or are planning to offer to your customers, etc.;
iii. information about your experiences with us or insurance carriers that underwrite insurance that we arrange for our clients including but not limited to bank or other entity claims information, employee claims information, policy coverages, limits, deductibles, endorsements and exclusions, regulatory actions, civil actions, criminal actions, etc.;
iv. information that we receive from external sources including but not limited to insurance carriers, managing general agencies and other insurance agencies that underwrite insurance that we arrange for our clients and/or with whom we work in servicing any of your insurance policies, banking regulatory agencies, insurance regulatory agencies, workers compensation rating agencies, consumer reporting agencies, public sources, etc. including but not limited to bank or other entity claims information or experience, employees’ claims information, regulatory actions, merger/acquisition information, payment history, driving history, real estate records, etc.;

We will use prudent security standards to protect your non-public personal and confidential information. We will protect against unauthorized access or use of this information. We maintain physical, electronic and procedural safeguards that comply with federal guidelines to guard your non-public personal and confidential information against unauthorized access or use. Our employees have access to you information only to the extent reasonably necessary to complete their responsibilities, to maintain servicing of your policies, to complete servicing or other actions authorized by you, to notify you of new products and services, or service you in our capacity as insurance agents or brokers. Our employees are subject to our corporate code of ethics and other policies that require maintaining confidentiality of client information. We will continue to enhance and maintain prudent security standards and procedures to protect against unauthorized access or use of your non-public personal and confidential information. These security procedures protect both current and former clients who have applied for any type of insurance product or service through our agencies whether or not such insurance policies were actually issued and/or such services were provided.

We will not share any non-public personal or confidential information about our clients within our corporate family, except as permitted by law or expressly authorized by our clients. If you have given confidential medical information to us, such as for insurance application or other permissible reasons, we will not share this confidential medical information either within or outside of our corporate family except in a manner disclosed to our clients at the time that the information is collected or to which you have agreed.

We will not share your non-public personal or confidential information with any company or third party outside our corporate family except as required or permitted by law. This means that we may disclose your confidential information in situations to include but not be limited to the following:

• to third parties that provide products and services to you such as insurance carriers, third party administrators, managing general agencies, other insurance agencies with whom we work in underwriting, brokering and servicing your insurance policies, etc.;
• to third parties that assist us in marketing products and services to you;
• to other insurance agencies or third parties with which we have joint marketing agreements to enhance our insurance product or service offerings;
• to third parties that process or service insurance products, services or transactions that you request or authorize;
• to respond to a subpoena, court order or judicial process;
• to our regulators and auditors;
• to protect against or prevent fraud, manage risk, or resolve client disputes; or
• to a third party to whom you specifically authorize us to share the information.

Whenever other companies or third parties provide services for us or on our behalf, we require them by contract to maintain the appropriate safeguards to ensure the security and the confidentiality of the information that we or you provide them. We will automatically limit the disclosure of your non-public personal and confidential information within and outside of our corporate family to what is permitted by applicable federal and state laws and regulations.