Liberty Associates, Inc. (“Liberty” or the “Firm”) may use electronic means to collect and maintain customer and counterparty information. This information may include personally identifying information for individuals such as social security numbers and confidential or sensitive information for institutional customers and counterparties, including corporate records and financial information. Additionally, Liberty may have a website that is available to customers and counterparties for opening accounts, trading, and accessing account information, and rely upon electronic means to enter customer, counterparty and proprietary orders. Liberty either directly or indirectly connect electronically with other regulated entities, exchanges, clearinghouses, third-party service providers, SEC and FINRA.
The Company has a supervisory obligation to assess and prioritize the risks associated with the use of our information technology systems, no matter how big or how small. We will rely on personnel from our information technology group (whether it is an internal group or an outside consulting firm), our back office, our internal and external risk management and compliance consultants, if applicable, to perform this assessment. If applicable, we will reach out to our internal and external auditors to assist in the assessment.
