New Federal Rule Regarding the Disposal of Sensitive Information Derived from Consumer Reports
November 21, 2005
As discussed in a previous Information Security and Internet Enforcement e-alert, a new federal rule went into effect on June 1, 2005, requiring businesses and individuals to take appropriate measures to dispose of sensitive information derived from consumer reports. See 16 C.F.R. ยง 682.1 et seq. Despite our initial e-alert, many clients continue to have questions regarding the Disposal Rule and its compliance requirements. As an initial matter, any business, large or small, or individual who uses a consumer report for a business purpose is subject to the requirements of the Disposal Rule, a part of the Fair and Accurate Credit Transactions Act of 2003 (FACTA).
For more information on how to comply, please contact one of the attorneys in Sonnenschein’s Labor & Employment Practice Group or Sonnenschein’s Information Security and Internet Enforcement Practice Group.
Click here to read the E-Alert.
These materials should not be considered as, or as a substitute for, legal advice and they are not intended to nor do they create an attorney-client relationship. Because the materials included here are general, they may not apply to your individual legal or factual circumstances. You should not take (or refrain from taking) any action based on the information you obtain from this document without first obtaining professional counsel and you should not send us confidential information without first speaking to one of our attorneys and receiving explicit authorization to do so.
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