As the old saying goes, “The job’s not finished until the paperwork is done.” But since the enactment of the FTC’s Disposal Rule, the job’s not finished until the paperwork – in this case, consumer reports or information derived from them – is securely destroyed. The Disposal Rule is the latest regulation to go under the microscope as part of the FTC’s regulatory review process. How is the Rule working at your company?
If you’ve pulled a report to consider, say, a credit request or employment application, you know they’re a treasure trove of sensitive information. But once you’ve made the credit or personnel decision, what happens to all that data? To keep it out of the hands of hackers, dumpster divers, and data thieves – and thereby reduce the risk of fraud and identity theft – the Disposal Rule requires that you take “reasonable measures” to ensure secure disposal.
The Rule covers the reports themselves and information derived from them. In addition, it applies to hard copies and data in electronic form.
As part of the FTC’s systematic review of rules and guides, we’re asking for your feedback on the Disposal Rule. What’s the economic impact? Have there been technological changes since the Rule took effect in 2005? You’ll want to read the Federal Register Notice for a list of questions, but one particular area of interest is whether the definition of “consumer information” should be expanded to include aggregate information or data that can be reasonably linked to an individual.
File your comment by November 21, 2016.
Looking for a refresher on what the Rule currently requires? Read Disposing of Consumer Report Information? Rule Tells How on the Business Center’s Credit Reporting portal.