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#127902 - 11/03/03 06:36 PM Gramm-Leach documents with ID's

GLB – documents locked-up - We recently had a training session on GLB and document lock-up was discussed.

Due to the nature of our business line (residential mortgage lending), it would be extremely difficult for everyone to clear their desks, and put away all files and papers daily. It would mean additional cabinets in an already crowded area, and lack of productivity, especially with underwriters who have multiple files out that they are working on.

Our building is “almost” secure. The only person who is allowed-in and not physically escorted is the cleaning person. To comply with GLB could either of these be used:

Arrange someone’s schedule to be with the cleaning person when he is in the building. This would mean altering someone’s schedule to come in late and leave when the cleaning person is finished.

Have the cleaning person become an employee of the bank. As an employee, it would be permissible for them to be around the documents.

Would either of those work, or might there be other things we can try? There is just no additional room for cabinets, nor the budget to buy them.

Thank you.

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Operations Compliance
#127903 - 11/03/03 06:54 PM Re: Gramm-Leach documents with ID's
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
Security and compliance are costs of doing business. Someone who works on the budget needs to understand that. You may need more offsite storage or additional space but that is what happens with growth.
Changing your workers' schedules does not seem reasonable, our cleaning crews come in all hours of the night and morning. I also think you would end up with a pretty expensive watchdog. Making the cleaning person/crew employees - not sure that would be any cheaper than making space.
My opinions are not legal advice and are worth what you paid for them.

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#127904 - 11/03/03 07:12 PM Re: Gramm-Leach documents with ID's
incandescent Offline
100 Club
Joined: Oct 2003
Posts: 125
Have the cleaning company and the actual person that is doing the cleaning sign a privacy agreement. If you feel that the company or person cannot be trusted, hire someone else that can be trusted.

The measure that you noted are way too expensive or not productive.

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