Your Company
It is very likely that, because of the information that you collect and store on a daily basis, your company is subject to the rules, regulations and penalties of multiple federal and state legislation that targets how companies protect and secure client and employee Personal and Private, Non-Public Information. That legislation would include but is not limited to the Fair and Accurate Credit Transactions Act (FACTA); Fair and Accurate Credit Transactions Act – RED FLAG RULES; Graham Leach Bliley Safeguard Rules; Fair Credit Reporting Act (FCRA); Health Insurance Protection and Portability Act (HIPPA); Individual State Legislation.
In response to the requirements of these legislations and in conjunction with the recommendations of the Federal Trade Commission, Bitto Financial Group will provide your company a policy binder for the Affirmative Defense Response System. This binder along with our in-person trainings will provide your company with the following, all of which are intended to respond to specific legislative requirements as well as create what the Federal Trade Commission refers to as a “Culture of Security”:
1. A written Sensitive Information Policy and Program.
2. On-Site Employee Identity Theft Training for all employees at all company locations.
3. Documentation for:
a. Owner or Board of Director adoption of Sensitive Information Policy.
b. Appointment of Company Information Security Officer.
c. Letter of acknowledgement by each employee of receipt of training and awareness of company policy.
d. Letter of acknowledgement by each employee of opportunity to enroll in optional company benefits for personal identity theft protection.
e. Company policy for addressing a response should identity theft occur in the workplace.
f. Transferring liability from your company to third party vendors (payroll, tax preparation, medical insurance, etc.) with whom you share employee and client sensitive information.
Your Employees
Make no mistake, one of the reasons that these rules now exist for companies is that nearly half of all identity information that is lost, is lost through and by companies. That statement is not meant to accuse your employees of stealing. The reality is that you want them (and we attempt to train them) to be “eyes and ears” for the company with respect to the sensitive information that your company collects. You want them to be part of the solution in identifying and reporting possible identity theft security problems.
Additionally, we will offer (as a payroll deduction) two reasonably priced optional benefits for their own Identity Theft Protection and Restoration. Both of these benefits are offered with no long term obligation on the part of the employer or employee and because you are offering the benefits as a group, the $10 enrollment fee is waived for the employee.
The first benefit is Identity Theft Shield which covers both the employee and their spouse or significant other and includes:
1. An initial credit report for both the employee and spouse or significant other, to make sure that their financial records are accurate.
2. Personal Credit Score and analysis.
3. Continuous (24/7) credit monitoring
4. Identity Restoration
a. Financial Accounts
b. Driver’s License
c. Social Security Number
d. Medical Information
e. Character/Criminal
The second benefit is Life Event Legal Plan, which covers the employee their spouse or significant other and their dependant children under the age of 21, living at home, includes:
1. Preventative Legal Services
a. Legal Consultation and Advice
b. Letter and Phone Calls
c. Contract and Document Review
d. Will Preparation
2. Motor Vehicle Legal Service
3. Trial Defense Services
4. IRS Audit Legal Services
5. 25% Discount on all legal services not covered by the plan.
6. A 24/7 – 365 Day per year immediate emergency access to legal help.
Identity Theft is the fastest growing crime in America today. If your company was to experience a security breach and lose some of this valuable information, either by theft or by accident, the possible penalties included in these legislations could result in substantial fines and/or forced federal oversight and regulation of your business practices. This could be in addition to separate civil actions taken by the victims themselves.
Betsy Broder at the Federal Trade Commission made a significant statement. She said “We‘re not looking for a perfect system, but we need to see that you’ve taken reasonable steps to protect your customer’s information.”
We agree that there most likely is no perfect system and the Affirmative Defense Response System certainly cannot guarantee that you would not experience an identity theft problem. We do believe that the implementation of the Affirmative Defense Response System for your company does constitute a series of significant reasonable steps toward protecting this valuable information and in responding to the requirements of the legislation.
The Affirmative Defense Response System is not only about helping companies to take preventative measures to protect this data. It is designed to help mitigate a company’s damage assessments, should the company experience this difficult situation.