A Kaulkin Ginsberg Publication
FICO
11/22/2009

How the New Red Flag Rules Impact Your Business

December 16, 2008
 
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When you are putting your plan into writing remember to list who to notify in the event of a security incident.  This might include the customer, or consumer, law enforcement, your attorney, the credit bureaus or other business owners that might be affected by a breach.

Your plan doesn’t have to be long and complicated, it should be written according to your company’s size and complexity.  Your plan must:

  • Designate one or more employees to coordinate the information security program, or be in charge of the program.
  • Identify and assess any risks to customer information and evaluate the effectiveness of your current safeguards for controlling those risks.
  • Write and implement a safeguards program, as well as monitor and  test it regularly. For example, what will you do if someone’s identity is stolen and what do you do now to prevent identity theft?
  • Screen service providers that meet your security measures and make sure they maintain those safeguards, and oversee their handling of your customers’ personal information.
  • Evaluate and adjust the plan as things change within your business, with the law or as the result of security testing and monitoring.

Your plan can be a single page, or multiple pages with many chapters.

Make sure you identify any unique risks your company might have, depending on the nature of your business. If you have employees that work from home, research and write a specific plan for those computers, emails and employees.

For more information on the rules or to educate yourself or your staff contact Michael Barnett at Barnett Training, www.BarnettTraining.com or visit the FTC website at www.ftc.gov.

Michelle Dunn helps companies that want to have customers that pay on time or early, she works with companies that are struggling with customers that pay late or don’t pay. Michelle has over 21 years experience in credit & debt collection, is the author many books and possesses a depth of knowledge and a whole tool kit of products and services that can make a big difference for your company. www.MichelleDunn.com & www.Credit-and-Collections.com

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