I would think that an annual for existing staff and an initial one for new hires would suffice. Combine it with Ethics. I personally hate to see us kill so many more trees than we need to, only to gripe about the filing. I'd also consider an electronic acknowledgment when available.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell