WHAT THIS MEANS

3.1   Encourage your clients to classify sensitive information as such. If they don’t, you must treat any and all information obtained from your client as confidential, unless it can be obtained through public inquiry.

3.2   Do not disclose any confidential client information without the specific consent of your client. The exception may be disclosure to other members of your consulting team, provided that you can be assured your team member(s) will also respect the confidentiality of the information.

3.3   Store confidential information in such a fashion that, through diligence and normally accepted administrative practices, you are assured of its security.  If, for example, information is stored on magnetic media, you and anyone authorized to access it must be cognizant at all times of the location of such media, including back-up material.  Destroy or make unintelligible any and all printed notes, drafts and reports before discarding them.

3.4        If confidential client information that has been obtained by you is, at any point in time, exposed to unauthorized individuals, you inform your client immediately and take appropriate action to protect your client's interests.

3.5   Upon termination of an assignment offer to return to your client any and all sensitive material pertaining to the engagement. You may keep engagement files for future reference. Of course, any sensitive information retained should be safeguarded with the same security precautions as during the engagement.

3.6   Refrain from making public statements that may directly or indirectly lead to the disclosure of confidential client information.

3.7   The rules pertaining to confidential client information do not apply to exchange of information with a recognized investigative body or compliance with a validly issued and enforceable subpoena and summons.

3.8        Confidentiality does not extend to criminal or illegal activity that you discover in the course of an assignment. You have a legal and ethical obligation to report such findings to the next higher level of management, or to the appropriate public agency (police, FBI, etc.) if the activity extends to your client’s governing board. To avoid surprises and a sense of violated confidentiality, you need to make your client aware of this limitation on your confidentiality.

© Copyright IMC USA 2002

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