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Congress passed the Gramm-Leach-Bliley Financial Modernization Act (“GLB
Act”) in 1999. The primary purpose of the GLB Act is to ensure that financial
institutions have an affirmative and continuing obligation to respect the privacy
of its customers and to protect the security and confidentiality of those customers’ non-public
personal information. The GLB Act defines “consumers” and “customers” and
sets forth a dealer’s requirements to notify the consumer/customer of
how the dealership handles any non-public personal information from such consumer/customer,
including any disclosure of such information to certain third parties.
The second phase of the GLB Act was designed to regulate how a dealer must
protect information about its customers. The dealers were required to be in
compliance by May 23, 2003. The second phase of the GLB Act, commonly referred
to as the Safeguards Rule, sets forth standards for developing, implementing
and maintaining reasonable administrative, technical and physical safeguards
to protect the security, confidentiality, and integrity of customer information.
The Rule applies to all customer information in your possession, regardless
of whether such information pertains to individuals with whom you have a customer
relationship or pertains to the customers of other financial institutions that
have provided such information to the dealer. Dealers must develop, implement
and maintain a comprehensive written information security program. Dealers
must also insure that service providers have implemented appropriate safeguards
to maintain customer information the dealer shares with them.
Does your dealership have a comprehensive Privacy Notice geared to the automotive
industry which it provides to your customers? What procedures do you follow?
Are your employees properly handling and maintaining Privacy Notices? Does
your dealership have a comprehensive written Information Security Program?
Do you have proper employee training and management as needed for Safeguards
Rule compliance?
Adams, Quinton & Paretti assists dealers in Privacy Act/Safeguards Rule
compliance at whatever level of assistance they need. Call us with your questions
and let us tell you how we can assist and protect your dealership regarding
these complex federal regulations. |
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