April 8, 2015
Many companies keep sensitive personal information about customers or employees in their files or on their network. Protecting customer NPI information is a vital part of conducting business. Federal and state laws (including the Gramm-Leach-Bliley Act) require title companies to develop a written information security program that describes their procedures to protect non-public customer information. Having a sound security plan in place to collect only what you need, keep it safe, and dispose of it securely can help you meet your legal obligations to protect that sensitive data. ALTA as well as the FTC have free resources for businesses of any size.
For attorneys and title agents, ensuring compliance with the ALTA guidelines comes at the same time that the title and settlement professionals are preparing to adopt the CFPB's new integrated mortgage disclosures that will be mandatory on August 1, 2015.
If you would like a complete set of assessment questions and templates with sample written procedures, please contact Deb Hall at firstname.lastname@example.org or feel free to call to discuss your plan to document and implement your written procedures.
Best Practice: Adopt and maintain a written privacy and information security program to protect Non-public Personal Information as required by local,
state, and federal law.
To assist you with your written procedures, attached are the following items:
ALTA Best Practices - Pillar 3
Security and NPI assessment questions and sample template for written procedures (Please change this form to reflect your office procedures. Review legal, contractual, and statutory requirements and incorporate those requirements in these procedures.)
The best practices framework provides standard assessment tools and consists of 7 pillars:
You can access tools, documents and find additional resources on the following websites:
ALTA website: www.alta.org/bestpractices
We've placed a copy of the ALTA Best Practices in EPIC under Member Access as well. If you have any questions, please contact us at 303-292-3055 or 800-525-6558 x0.