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Safeguards

The Gramm-Leach-Bliley Act requires financial institutions to put safeguards into place to protect consumer non-public information.  By denying waver requests, the Federal Trade Commission (FTC) has recently broadened "financial institutions" to include most types of mortgage companies and essentially all car dealers.  In addition, the FTC has made "safeguards" very precise.  All financial institutions must:

  1. Designate someone to coordinate the safeguards.
  2. Identify and assess the risks to customer information and 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 appropriate service providers and contract with them to implement safeguards.
  5. Evaluate and adjust the program in light of relevant circumstances, including business changes or testing and monitoring of safeguards.

Rule 3 states that not only do you  need to put up firewalls and other security mechanisms but you also need to regularly monitor and test them.  BSI's Sentinel and Sentinel Services provides you with regular monitoring and testing.

For further information, please email bristolsystems.com, username solutions.

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