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Keith Whann

--Keith Whann--
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--Keith Whann--
Keith Whann
On 10/30/16, 12:51 PM

Following the FTC’s Privacy and Safeguards Rules are an important first step in protecting your dealership. Motor vehicle dealerships are required to provide their customers with a Privacy Notice that advises the customer about the types of information the dealership collects, the sources from which the information may be obtained, and the dealership’s policies with respect to sharing that information. In order to fully comply with the Gramm-Leach-Bliley Act and the FTC’s Privacy Rule, motor vehicle dealers are also required to make a statement about their information safeguarding practices in their Privacy Notices. Pursuant to the Safeguards Rule, dealers must also have a written document that specifies the steps they have taken to assess the types of risks that exist with respect to the information being obtained by unauthorized individuals and to protect the confidentiality and security of such information. The FTC’s Safeguards Rule specifically requires every dealer, regardless of the size of his dealership, to develop, implement and maintain a comprehensive written information security plan that describes the dealership’s program to protect customer information. The Dealership must: (1) Designate an employee or employees to coordinate the safeguards program; (2) Identify and assess the risks to customer information in each relevant area of the dealership’s operation, and evaluate the effectiveness of the current safeguards for controlling these risks; (3) Design and implement a safeguards program, and regularly monitor and test it; (4) Select service providers capable of maintaining appropriate safeguards for the customer information the dealership shares and require them to agree contractually to do so; and (5) Evaluate and adjust the program as appropriate.

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Asked: 10/30/16, 12:51 PM
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Last updated: 10/30/16, 12:51 PM