well as the recently updated Safeguards Rules that went into effect on June 9, 2023. The Safeguards Rule does NOT require data deletion from vehicles. That being said, it is in the best interest of every dealer to adopt industry best practices when it comes to data deletion of customer PI in order to promote consumer trust and limit possible future litigation. Some potential best practices dealerships might want to consider include: 1. Developing and implementing a secure data deletion policy that identifies all types of PI captured by vehicles and the process the dealership follows to delete the information as an optional service for their customers. 2. Preparing disclosures dealership staff can provide consumers, including: a. A general disclosure for computerized vehicles capable of data collection, transmission, and sharing with OEMs or any third parties. b. A disclosure for vehicle owners about data inside the vehicle the dealership may share with that vehicle’s OEM and vice versa. c. A disclosure to vehicle owners that data will be captured and stored within the vehicle itself, noting the vehicle owner’s manual will provide them with instructions on how to erase the data stored prior to trading in or ending a lease. Potential alternative ways to delete in-vehicle PI could involve telling authorized personnel that they are responsible for deleting PI from the vehicle, providing employees with tools to delete PI, or contracting a third party to delete the PI. While data deletion is not required under the Safeguards Rule, it makes sense for dealerships to consider how they want to address this important issue that can benefit both their customer service AND their bottom line. Developing a consistent and compliant policy using common best practices will help dealerships protect themselves from potential litigation, build brand reputation, and improve consumer trust as technology continues to evolve in the auto industry. Johanna Stubenhofer is NJ CAR’s Communications Associate and can be reached at jstubenhofer@njcar.org. … IT IS IN THE BEST INTEREST OF EVERY DEALER TO ADOPT INDUSTRY BEST PRACTICES WHEN IT COMES TO DATA DELETION … continued from page 26 28 new jersey auto retailer
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