ALTA- Pillar 3
PILLAR 3 - PROTECTING NON PUBLIC INFORMATION- GUARANTEED FLORIDA TITLE MEETS THIS BEST PRACTICE PILLAR BY USE OF CITRIX® SHAREFILE® A SECURE COMMUNICATION AND DOCUMENT DELIVERY SERVICE DESIGNED FOR TITLE, ESCROW AND REAL ESTATE COMPANIES TO PROTECT NPI, WHICH PROTECTS OUR CLIENT’S NON-PUBLIC PERSONAL INFORMATION AND PROVIDES FILE ACCESS CONTROLS TO SECURE EXTERNAL EMAIL COMMUNICATION AND ELECTRONIC DOCUMENT DELIVERY, OUR ELECTRONIC OFFICE MANAGEMENT SYSTEM SECURES OUR CLIENT’S DATA. WHEN FACED WITH A RECIPIENT LENDER THAT CANNOT WORK WITH SHAREFILE®, WE FAX THE MATERIAL TO A SECURE FACSIMILE MACHINE OF THE LENDER.
Policies and Procedures
Privacy and Information Security
Document a privacy and information security program (policies and procedures) to ensure Guaranteed Florida Title, Inc. maintains written protocols for the protection of data and Non-public Personal Information (NPI).
These policies and procedures are for all of Guaranteed Florida Title, Inc. (hereafter referred to as “The Company”) locations including all satellite offices. These procedures are to be followed by all employees and independent contractors where applicable
The Company policies associated with the privacy and information security program are given to all employees and the employees must acknowledge in writing that they have read and understand such policies. It is the responsibility of Office Manager to ensure The Company has received all employee acknowledgements.
The Company makes an assessment on an annual basis of the standards and requirements affiliated with The Company’s information security program, including those set out in this policy and procedure document. This assessment is conducted by ProCirrus Technologies, Inc. and a formal report on compliance is issued to The Company management.
Physical Security of NPI
The Company utilizes Insperity, Inc. as the information provider for background and credit checks. The Company individuals who have access to NPI is restricted to authorized principals and employees who have undergone a formal background check and credit report process which identified no irregularities.
Removable media devices, including but not limited to external hard drives, compact discs, magnetic tapes and USB/flash drives are
issued by the Company with the approval of the President & CEO. The use of removable media devices is prohibited unless the President & CEO has authorized such use. Removable media is kept in a secure area and accounted for via the Office Manager when not in use.
Other standard procedures for security of NPI include closing paper files other than the one currently being worked on, stow files away when away from workspace and lock desks and file cabinets at the end of the day. Hardcopy NPI that is transmitted outside The Company is done so using only secured envelopes and/or locked document bags. The Company uses a GBC GLM11 Shredmaster which micro cuts documents, providing security level 4 shredding.
Network Security of NPI
At the direction of the President & CEO, The Company’s designated Network Administrator grants appropriate access to The Company’s various computer technology applications. The Company’s keeps all of its application data in on a secure Cloud environment. The Company’s Cloud and workstations utilize up-to-date anti-virus, anti-spyware and data encryption software applications. The Network Administrator is responsible for such software maintenance.
Myron E. Siegel, President & CEO
June 1, 2014
|Date of Commencement
June 1, 2014
June 1, 2016
|Date for Next Review
August 31, 2017
|Related References and Links
Internal Company Policies:
Policies and procedures relating to privacy and information security are kept on the Guaranteed Florida Title, Inc. Cloud network “R” drive in a folder entitled “Privacy and Information Security”, document name “Privacy and Information Security P-P”.
The Company's information security program and disaster management plan are kept on the network Cloud R drive in a folder entitled “Privacy and Information Security”./p>
PURPOSE OF THIS NOTICE
TITLE V OF THE GRAMM-LEACH-BLILEY ACT (GLBA) GENERALLY PROHIBITS ANY FINANCIAL INSTITUTION, DIRECTLY OR THROUGH ITS AFFILIATES, FROM SHARING NONPUBLIC PERSONAL INFORMATION ABOUT YOU WITH A NONAFFILIATED THIRD PARTY UNLESS THE INSTITUTION PROVIDES YOU WITH A NOTICE OF ITS PRIVACY POLICIES AND PRACTICES, SUCH AS THE TYPE OF INFORMATION THAT IT COLLECTS ABOUT YOU AND THE CATEGORIES OF PERSONS OR ENTITIES TO WHOM IT MAY BE DISCLOSED. IN COMPLIANCE WITH THE GLBA, WE ARE PROVIDING YOU WITH THIS DOCUMENT, WHICH NOTIFIES YOU OF THE PRIVACY POLICIES AND PRACTICES OF GUARANTEED FLORIDA TITLE, INC. . . .
We may collect nonpublic personal information about you from the following sources:
- • Information we receive from you such as on applications or other forms.
- • Information about your transactions we secure from our files, or from [our affiliates or] others.
- • Information we receive from a consumer reporting agency.
- • Information that we receive from others involved in your transaction, such as the real estate agent or lender.
We may disclose any of the above information that we collect about our customers or former customers to our affiliates or to nonaffiliated third parties as permitted by law.
We also may disclose this information about our customers or former customers to the following types of nonaffiliated companies that perform services on our behalf or with whom we have joint marketing agreements:
- • Financial service providers such as companies engaged in banking, consumer finance, securities and insurance.
- • Non-financial companies such as envelope stuffers and other fulfillment service providers.
WE DO NOT DISCLOSE ANY NONPUBLIC PERSONAL INFORMATION ABOUT OUR CLIENTS WITH ANYONE FOR ANY PURPOSE THAT IS NOT SPECIFICALLY PERMITTED BY LAW.
We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
RECORDS AND INFORMATION MANAGEMENT CONSENT AND ACKNOWLEDGEMENT FORM
This will certify that I have read and understand the “Guaranteed Florida Title, Inc. Non-Public Personal Information Policy”. Furthermore, I also understand that Guaranteed Florida Title, Inc. is committed to protecting its records and fully complying with all applicable laws and regulations.
I understand that when I have a concern about a possible violation of this Policy, I have a duty to report the concern to management. I further understand that this Policy does not constitute a contract and may be modified from time to time by Guaranteed Florida Title, Inc. with or without notice.
Print Name of Employee/Consultant/Contractor
Signature of Employee/Consultant/Contractor Date