Client Policy – Website Usage
June 24, 2004
SII Investments, Inc. Compliance Updates represent a modification or clarification of the Firm’s written policies and procedures. The information contained herein supersedes any and all information related to the above-entitled issue that had previously been distributed by SII. The Update is considered to be a formal amendment to the Firm’s supervisory procedures as of the above date. All Registered and Associated persons are responsible to read and understand this Compliance Update which is incorporated into SII’s WRITTEN SUPERVISORY PROCEDURES available at www.siionline.com.
We have seen an increase in state level regulations regarding business websites having the ability to collect client data (i.e. client name, email address, mailing address, etc.). To comply with these regulations, all Representatives who host or facilitate a securities-related website/webpages must post the appropriate privacy policy link(s) on their sites. This also includes Representatives who use a third party website to market their services (i.e. Representatives who have partnered with a Financial Institution, where the primary website is hosted by the Financial Institution but the Representative’s services are listed therein).
Effective July 1, 2004, the following requirements must be in place for Representatives who host/facilitate a securities related website/webpages.
- Post a text or icon hyperlink from the Home Page of their securities-related website entitled “SII Privacy Policy”. This link must route to https://www.siionline.com/public/forms/sii_madv6130a.pdf
- If the website discusses products and/or services not provided through SII, a separate Privacy Policy related to these issues must be posted. SII cannot provide Legal advice related to the creation or posting of this Privacy Policy, nor should SII be listed by name in this policy.
Text Link Requirements
- Must be written in capital letters equal to or greater in size than the surrounding text; or
- Must appear in contrasting type, font, or color to the surrounding text of the same size, or offset from the surrounding text of the same size by symbols or other marks that call attention to the language.
Icon Link Requirements
- Must be titled “SII Privacy Policy” and appear in a color contrasting the background color of the webpage or must be otherwise distinguishable.
Note: Although SII is solely concerned with securities-related websites, Representatives who currently host a non-securities related site should also comply with this requirement. Many states now require such information to be posted to business-oriented websites.
As part of our surveillance process, we will be conducting random reviews of websites to ensure Representatives are in Compliance with this requirement.
Attention Representatives who utilize Emerald or Advisorsquare: SII now requires these providers to post a link to the SII Privacy Policy on all securities related websites. Responsibility for posting privacy policy information regarding non-securities related products and/or services remains with the Representative.
If you have questions regarding these new policies, which take effect July 1, 2004, please contact the SII Compliance Department at 800-426-5975, option 3.