Compliance is Pretty Important, I Guess Florida Gulf Coast ARMA Meeting

Introduction and Disclaimer I’m Me I’m Not Your Attorney (at least not yet…)

Overview Perspective on Compliance Financial Compliance Elements Areas of Concern Recommendations Q & A

Perspective on Compliance Perfect Compliance Reasonable Standard of Professional Care

Financial Compliance Elements Client/Record Types  Student Records  Bank Records  Auto Loans  Corporate  Explanation of Benefits  Credit Reports  Credit Card Information Laws/Standards  Family Educational Rights and Privacy Act (FERPA)  Gramm-Leach-Bliley (GLBA)  Sarbanes-Oxley (SOX)  HIPAA  Fair and Accurate Credit Transactions Act (FACTA)  Fair Credit Reporting Act (FCRA)  Payment Card Industry Data Security Standard (PCI)

Areas of Concern Access/Transmission  Privacy and Security vs Accessibility Maintenance  Hard Copies  Digital Copies  Data

Recommendations Know Your Clients Know Yourself Know Your Vendors (Kn)Adjust As Needed

Recommendations Know Your Clients

Recommendations Know Yourself  Risk Assessments  Product Specific Issues  Third Party Audits  Controls

Recommendations Know Your Vendors  Subcontractor Agreements  Digital Records Vendors  Software/IT Solutions

Recommendations (Kn)Adjust As Needed Business Associate Agreements Vendor Agreements Internal Policies and Procedures Training

Any Questions?

Mark Hinely Regulatory Compliance Specialist KirkpatrickPrice