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 HinelyRegulatory Compliance Specialist

KirkpatrickPricem.hinely@kirkpatrickprice.com

850.339.5963