Your salespeople probably listen regularly to your customers’ concerns about protection of their private information. You’ve put in place safeguards to protect that information as required by federal law, and you notify customers of your policy through a privacy notice. You’ve locked file rooms, locked F&I offices, and put in any number of physical and electronic protections against information breaches. But here are some things you may have overlooked.
Equipment with a memory. Hopefully, when you dispose of a computer you take steps to reformat the hard drive to wipe out all information. However, today’s copiers, faxes, printers, and scanners keep an electronic copy of any documents you are processing through them in an internal memory. Unless you wipe out that memory, when you trade in your equipment, send it to the dump, or give it to the local school, pages and pages of material containing confidential information will still be in the machine. Before disposing of electronic equipment with a memory, make sure you wipe the equipment clear of any stored information. Discuss this with the vendor selling you the replacement equipment to make sure that you get it right.
Portable Devices. You have safeguards on your computer system. You protect against external and internal intrusions. You have adopted a password protocol, and you make sure that employees only have access to customer files for the purposes of doing their jobs. However, to what types of devices can employees with access download the information? If they can download it to portable PCs, workpads, and smartphones, you may wind up with some substantial confidential information on these personnel devices. What happens if an employee leaves your employ with this information? What happens if an employee loses his or her PC, workpad, or smartphone? Make sure you control the ability to download to personal devices.
Invoices and Deal Documents. You want your salespeople to follow up with customers to whom they sell vehicles. So you give them “invoices” or other deal documents to keep track. Is the employee keeping those documents under lock and key to protect them? And what happens to them when the employee leaves? The company’s deal documents belong to the company. Make sure that deal documents are safeguarded by the company’s system and that they are not in the personal files of salespeople.