you may be off the hook, but not out of the woods.
by donny shimamoto
management consulting company aon described an exemption for some of the ftc requirements for firms that handle the personal identifiable information (pii) of less than 5,000 consumers.[i]
the safeguards rule provides an exception from certain requirements if the covered financial institution maintains customer information concerning fewer than 5,000 consumers. a consumer is defined in section 314.2(b)(1) of the safeguards rule as “an individual who obtains or has obtained a financial product or service from the financial institution that is used primarily for personal, family, or household purposes, or that individual’s legal representative.”
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essentially if you handle less than 5,000 social security numbers, then it would appear that you can take advantage of this exemption. aon went on to report that if you fall under this exemption, then you do not need to address the following requirements:
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