Are Your Document Destruction Policies and Practices FACTually Compliant?

FTC Implements Final Rule on Disposal of Consumer Information

Does your company have a formal policy for properly disposing of records containing consumer information?  If not, it may be in violation of the new Final Rule implemented by the Federal Trade Commission under the federal Fair and Accurate Credit Transactions Act of 2003 (the FACT Act), which very recently took effect. 

This Final Rule generally requires “persons” (including employers) that maintain records about individuals that (1) qualify as consumer reports, (2) are derived from consumer reports, or (3) amount to a compilation of information from a consumer report to dispose of these records properly by taking “reasonable measures” to protect the information contained in them from unauthorized access or use in connection with its disposal.