expenditures of monies for new software to accomplish this requirement, and there is an additional requirement to oversee management procedures to access consumer information. Interestingly, the Rule asks that consumer information be deleted after two years, which we, as dealerships, cannot do, but there are “business purpose” exceptions. Unfortunately, this means that dealerships are going to have to evaluate this, justify the business exception, and create more formalized document retention and destruction policies. Of course, all this is going to require initial and ongoing training for all personnel, which will be required to be documented and verified. Last, one of the most challenging tasks, after determining who has access to your customers’ information, is then reviewing the contracts of vendors and determining if the vendors are complying with the new Safeguard Rules. I would recommend reaching out to these vendors and requesting updated contracts or addendums which are Safeguard Rule compliant. They also need to communicate to you how they are becoming compliant with the new Safeguard Rule. This will be quite a challenge, so I recommend starting now. I have been informed that NADA is putting out a Driven guide soon with templates to consider. This will be very helpful, and in the legal world, forms are dangerous if applied blindly without thought and consideration about how you do business and an evaluation of your individual needs and exposures. I strongly encourage you to reach out to knowledgeable counsel, and as always, the Association stands ready to assist you. t Committed to Client Success federatedinsurance.com Commercial Insurance Property & Casualty Life & Disability Income | Workers Compensation Business Succession and Estate Planning | Bonding Federated Mutual Insurance Company and its subsidiaries* *Not licensed in all states. 20.09 Ed. 3/21 © 2019 Federated Mutual Insurance Company Brokerage | Leasing | Appraisal | Consulting 304-840-1781 | Quintie Smith at INVS@aol.com | 3818 MacCorkle Avenue SE Charleston, WV 25304 Office: 304-925-7000 | Website: realcorpinc.com An unmatched level of knowledge and experience in the real estate market. Commercial Real Estate Issue 4 2021 23 WVADA
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