• GLB states dealerships have “an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers’ nonpublic personal information”
  • Safeguard Rule requires dealerships to have appropriate procedures designed to:
    • “insure the security and confidentiality of customer information”
    • “protect against any anticipated threats or hazards to the security or integrity of such information”
    • “protect against unauthorized access to or use of such information”
  • Requirements:
    • Designate an employee coordinator
    • Identify the risks
    • Design the program
    • Document the program
    • Distribute the program
    • Employee Acknowledgements
    • Service Provider Acknowledgements
    • Evaluate the program – You are guarding against issues with any person – not just a certain look or ethnicity
  • Points to remember about customer information:
    • Must ALWAYS be kept confidential
    • Paper needs to be secured or destroyed
    • Electronic data needs to be protected
    • Logout of computers
    • Data must stay on company systems
    • Can NEVER be used for personal reasons

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