Every firm is required to have their own privacy policy. Members often forget to send out the policy to their customers. When a customer account is opened, send a copy of your privacy policy to your customer and on an annual basis thereafter. For more information visit the Privacy Policy Questionnaire.
Tip: Make a record of when you send out your privacy policy. Sending your FCM's policy is not sufficient. However, an FCM can send out the privacy policy on behalf of its GIB, as long as the policy mentions both the FCM's and GIB's name.