From whom non-public personal information is received

How NPPI is physically and electronically safeguarded and protected

The split of title insurance premium between the title insurer and title agent

With whom non-public personal information is shared

Employee management and training

Information system security

Employee retention and remuneration

Detecting and managing system failures

Using anti-virus and anti-spyware software that updates automatically

Maintaining up-to-date firewalls, particularly if using a broadband Internet connection or allowing employees to connect to the network from home or other off-site locations

Promptly passing along information and instructions to employees regarding new securit risks or breaches

Checking with software vendors regularly for updates for TRID Closing Disclosures

Only the title agency is required to provide disclosure

The title company and title agnecy must each provide separate disclosure

Only the title company is required to provide disclosure

The title company and title agency may provide a single joint disclosure

Definition of marketable title

Procedures used to protect customer information

Effect or variable rate financing

Affiliated business relationship

In conjunction with affiliated business disclosure statement

At the time the customer relationship is established

At the closing, as part of the closing affidavit

Post-closing, at point of policy issuance

Promptly making a title claim under the company's errors and omission policy

Preserving and reviewing files or programs that may reveal how the breach occurred

Bringing in security professionals to help assess the breach as soon as possible

Immediately securing information that has or may have been compromised

Destroying or erasing data when disposing of computers, disks, CDs, magnetic tapes, hard drives, laptops, PDAs, Cell phones, or any other electronic media or hardware containing customer infromation

Burning, pulverizing, or shredding papers cantaining customer information so information cannot be read or reconstructed

Checking references/certification before hiring an outside disposal company

Tearing documents in half and putting them in a non-transparent trash bag before throwing th bags into the dumpster behind your office

Privacy Notice

Affiliated Business Disclosure

Truth in Lending Statement

Good Faith Estimate

Cautioning customers against transmittilg sensitive data, like account numbers, via email or in response to an unsolicited email or pop-up message

Hand delivering all TRID Loan Estimates and Closing Disclosures directly to the borrower

When collecting information online directly from the customer, making secure transmission automatic

Encrypting data when transmitting sensitive data by email over the internet

Credit card numbers

Public records information

Income and credit history

Certificates of deposit

Maintaining adequaate errors and omissions insurance, fidelity bond, and surety bond.

Ensuring that storage areas are protected against destruction or damage from physical hazards like fire

Maintaining careful inventory of company computers and any other equitment on which customer information may be stored.

Avoiding storing sensitive customer data on a computer with an Internet connection

Encrypting sensitive customer information when it is transmitted electronically via public networks

Outsourcing title searches to the title insurer or independent abstractor

Locking rooms and file cabinets where records are kept

Not sharing or openly posting employee passwords in work areas

Identification data: name/ birth date/ social security number

Information obtained through public records in the jurisdiction where the subject property is located

Income, asset/liability and credit histories

Bank and credit card numbers, balances, and payment history

Non-public personal information

Warrenty deeds and affidavits

Escrow deposits

Loan proceeds