- 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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