Step by Step Guide to Becoming FACTA Compliant
Becoming FACTA Compliant
1. Appoint a Security Officer. This should be an Executive Officer of the company or someone on the Board of Directors.
2. Develop an internal company policy regarding proper keeping and disposal of sensitive information or documents. This includes ANY consumer information. According to FACTA, "consumer information" is considered to be "any record about an individual, whther in paper, electronic, or other form..." Furthermore, FACTA requires that "information that identifies particular individuals" be securely destroyed. This includes something even as simple as a persons address or e-mail address. Included in the policies and procedures that should be covered are:
a. A retention schedule mandating when certain records must be securely destroyed.
b. A well defined, step by step procedure for various types of data and documents, including procedures for collecting and protecting the documents and data until the time that it is destroyed. For example, there might be provisions for secured, locked bins to collect data and documents until they are properly disposed of.
c. Certification of Destruction, showing exactly what was destroyed and when.
d. A program outlining a schedule for data and document disposal. For example, hiring a shredding contractor and being put on a consistent schedule. The "Certificate of Destruction" they provide you will reinforce your policy and provide important documentation.
3. Add this policy to your employee handbook and make sure each employee is aware of how materials are supposed to be disposed of. This can be achieved by a simple documented meeting or by having each employee sign something saying they understand and will follow the company policy.
4. Hire a shredding contractor, but show due diligence in doing so. Contact references they provide you. Ask for a copy of their liability policy for your records. Research them through the Better Business Bureau, Chamber of Commerce, etc. Even ask to visit their facility and have them give you a tour. Make sure to enter into an agreement stating that all materials will be properly destroyed in accordance with FACTA and maintain a copy for your records. Additionally, make sure you are set up on a schedule, which will show consistency in action and intent if the question should ever arise.
It sounds like a lot of work, but we are here to make it very easy on your company! Simply contact us and we will be happy to provide you with a basic retention schedule off which to work, basic company policies and procedures that can be enhanced if so desired, a list of references, a facility tour, an agreement stating we will destroy all materials to FACTAs standards, an agreement you can have your employees sign stating they understand your policies, etc.
4563 Mariotti Court #101
Sarasota, FL. 34233
(941) 927-7586
(941) 923-7504 fax
sdshred@yahoo.com
Monday - Friday
9 AM - 4 PM
