For the most basic of daily money management services, which is bill paying facilitation and account reconciliation, I would need access to information about your accounts on a monthly basis.

This access can take the form from the basics of you providing me a copy of your statements (paper form) each month, through giving me electronic access to download data. The specifics will depend upon our service agreement and your level of comfort. 

For more in-depth services, such as acting as a liaison with medical providers and government agencies, I may require more sensitive information such as your social security number, date of birth, etc. as well as signed “Release of Information” or “HIPAA Releases” that give permission for other companies or agencies to release information to me.

If you ask me to prepare “Life Binder” services in conjunction of my daily money management duties, I will need access and copies to all of your sensitive data including those mentioned above and others such as Military discharge / service records, lists and locations of assets, and the like.

In general, it is not in your best interest to share sensitive information unless it is necessary to perform tasks for you.  If I am given such data, I offer a great level of security regarding its protection. (See How this Information is Stored below)

As much as possible and to the greatest extent possible, I prefer to NOT share client’s passwords to accounts, but rather establish “Accountants” access through separate logins.

However, that is not always feasible or offered by financial institutions.

If we must resort to password/account sharing in order for me to get the data needed to complete my work for you, we will use a password “locker” to share these passwords (LastPass – no cost to you). You, or another you’ve delegated, will have full access and ability to change passwords as you wish and these changes will be automatically, and securely updated.

As policy, I update passwords every quarter, unless required to do so more frequently. Again, these updates will be shared automatically so that you’re never “locked out” of your accounts.

That said, I will not have the passwords/login credentials for your (or others if you’ve given permission) portal.

If you have neither internet access nor have a trusted second person who does, we can make other arrangements, such as you having a written copy (stored in a locked or safe location) while I use the online “locker” and provide you with updates as needed.

Physical Documents:
Unless absolutely necessary, and even then for only a brief period of time (for example, to make copies), I will not take or store original copies of statements, forms, or other documents. For these physical documents, I will help you develop a home filing system and if necessary help you maintain it as necessary or make other recommendations (for example, a will should be in a safe deposit box), as I do not have the room to store physical copies of client data.

Any physical copies I make that are later converted to electronic copies are shredded.

Electronic Data:  The general process is for me to work from electronic copies of information. This is either by you or me directly downloading various documents in needed file formation to me making electronic copies of any print/physical information. All of this is kept stored and accessible through a client portal, to which you (and others you give permission) will have unique login credentials. This portal, powered by TaxDome, is especially geared toward protecting sensitive financial and medical information. You, or others you designate, will have 24/7 access to the portal using a unique login and password combination.  TaxDome supports two-factor authentication.

To learn more about our portal (via TaxDome), and its data security practices, please see TaxDome’s policies for this detailed information. 

Electronic information, such as bank data files (if I do not have access to retrieve them myself on your behalf), can be securely uploaded to the portal for me to access and use.  Likewise, you may upload scanned documents and other information, if you are not having me do that for you. If you do not have or want portal access, I can provide a secure link, which is preferred over sending documents over email, or I can do the scanning or data retrieval tasks for you.

Tax Returns: Tax returns and anything with your social security number will be stored zipped with a password.  This password will be kept as agreed to or through LastPass. 

Storage and Backups: The portal will also be the repository of any data files, reports, budgets, and notes that you can access at any time. It may be that you’ll have a physical filing system at home for original copies and electronic copies of it (and the other records I produce) in the portal. Backups are made automatically once per week and are stored on an encrypted physical hard drive.

Emails: Although most of the correspondence is encouraged through TaxDome’s messaging features, I realize some clients may prefer email. As a rule, I will not send sensitive information through email and encourage my clients to use the alternative methods I’ve provided to share sensitive data.

This is your life and your data. I am simply providing a service.

You have the right to access your portal at any time to view all documents.

If you do not want portal access and are hesitant about keeping your data online, I can keep your data offline and on a secondary, encrypted hard drive. I do not have physical room to keep physical copies of records, so there must be some electronic storage of some type.

If you elect to terminate services, or I can no longer provide services, I will provide a zip file download of your files and give them to you. This will include pdf files, reports, Quicken/Quickbooks data files or anything obtained or generated during my service.

That said, online archives are kept for only 5 years. Anything 6 years or older are zipped and given to you or another designated by you.

Access Granted to Me:  To perform many of my services, you will need to grant me some level of access to information. This information is kept confidential and not shared with anyone without your express, written permission.

I will often use third-party online software to store, process and compile the information into useful reports. These services do not use your information in any capacity other than to provide the services per contract. I also use automation tools, such as Zapier, to help manage and automate tasks. These tools are not used to handle sensitive documents.

Access Granted to Others:  There may be cases where, with your permission, I will share your personal and financial data with others. This may include accountants, attorneys, financial planners, etc. This may also include those you have granted Power of Attorney, although the data I share will be limited to the scope of that agreement.

I have Business Associate Agreements (BAA) with TaxDome (client portal) and other service providers that may come in contact with Private Health Information (PHI) or sensitive Financial documents (especially those with social security numbers or account numbers). I use two-factor authentication wherever it is available.

As a rule, I do not share such documents via email and encourage clients and their representatives to do the same. I will provide secure links to allow for file uploads.

For offline files, I keep them on an encrypted hard drive. My laptop also requires biometric identification to log in.

All data and information regarding a client are never disclosed unless agreed to in writing or as otherwise required by law, a court order, or other legally compelling reason.

Even if services are paid for by someone other than the client (guardianship or similar type of arrangements excluded), the client has full rights and say-so over who gets access and to what degree.

During the onboarding process for each client, regardless of life circumstances, I address directly what is the course of action if the client is engaging in erratic or negligent spending that can threaten their financial stability and providing necessities. The client has the right to say I can do nothing; other times they may give me the name of a trusted individual to contact if outlined intervention steps have not worked.

Intervention Steps:  To re-iterate, how the client chooses to spend their money is not my business. I do not judge but will provide good advice to help them keep within a budget and achieve their goals.

If the client has agreed to let me contact another if things have gotten too far out of hand, we will have at least done the following:

* Gave repeated (3) notifications that spending is jeopardizing their budget.

* Discussed with them their spending and suggested ideas to assist (such as a capped limit or prepaid card).

Exceptions: The only time I will make exceptions is if there are multiple, documented examples of Financial Abuse. In that case, I will alert the trusted contact before the intervention steps or authorities as appropriate.