Disposal of Consumer Information
Question: In light of the final rule on proper disposal of consumer information, is there more that financial institutions need to do? In other words, does this require more than G-L-B information security and privacy?
Answer: As a practical matter, if your institution has done an effective job at designing and maintaining an information security program, you may be most of the way home - if not all of the way. The critical issues are information security and disposal of information - particularly those old denied loan applications. That being said, this is not a time to rely on assumptions. It is most definitely the time to take assessments of where the consumer report information exists and whether it is always adequately secure.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 15, 12/04
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