SUNCOAST TARPON SHOOT-OUT
INFORMATION SAFEGUARD RULES
POLICY AND PROCEDURE INFORMATION AND GUIDELINES
The Graham-Leach-Bliley Act, which became law on November 12, 1999, contains rules requiring a financial institution to safeguard the confidentiality of any “nonpublic personal information” which it has about a customer. The Federal Trade Commission, as a further interpretation of the Graham-Leach-Bliley Act, has implemented the FTC Information Safeguarding Rule, which sets a standard for handling personal information for all motor vehicle dealers who offer finance and insurance products. Suncoast Tarpon Shoot-out, as a full service recreational vehicle dealership, has implemented policy and procedure to ensure complete and voluntary compliance with this Act.
RECOGNITION OF EXPECTATION OF PRIVACY
Suncoast Tarpon Shoot-out has always valued its customers’ privacy. We have protected your confidential information in many ways for over thirty years and will continue to do so. At Suncoast Tarpon Shoot-out, the basis of each customer relationship is trust. We will never lose sight of the fact that our customer’s trust is our most treasured asset. You have chosen to do business with us, and we are obliged to honor that relationship with great care, beginning with the information that you have chosen to share with us. We believe that your privacy should never be compromised.
The business approach and control procedures outlined in this policy allow us to carry out our business of providing you with the best customer service and ease of transaction and safeguard your personal and private information.
COLLECTION, USE, AND RETENTION OF CUSTOMER INFORMATION
Suncoast Tarpon Shoot-out collects, retains and uses information about individual customers only where law allows it and the dealership believes it is useful in administering the dealerships’ business in providing products, services and other opportunities to our customers. Suncoast Tarpon Shoot-out does not currently sell data and does not have any future plans to change our policy on selling data.
LIMITING EMPLOYEES ACCESS TO INFORMATION
Only management level employees have access to retained confidential customer information. Confidential customer information collected by other staff is used only for specific directed reasons and tasks, is not reproduced or retained in any way, and is turned over to management at the earliest possible time.
PROTECTION OF INFORMATION VIA ESTABLISHED SECURITY PROCEDURES
Suncoast Tarpon Shoot-out maintains appropriate security procedures regarding unauthorized access to customer information.
RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION
Suncoast Tarpon Shoot-out does not reveal specific information about our customers or their transactions to unaffiliated third parties for their independent use, unless the information is provided: 1) to help complete a customer-initiated request, 2) to help administer the dealership’s bona fide business, 3) at the customer’s request, 4) to comply with a legal requirement (i.e. subpoena or other legal and valid court order), 5) to a reputable information reporting agency (i.e. credit bureau) or 6) after the customer has been informed about the possibility of such a disclosure through a prior communication and is given the opportunity to decline (i.e. “opt out”).
MAINTAINING CUSTOMER PRIVACY IN BUSINESS RELATIONSHIPS WITH THIRD PARTIES
Whenever Suncoast Tarpon Shoot-out does provide specifically identifiable customer information to a third party, Suncoast Tarpon Shoot-out insists that the third party adhere to similar “privacy principles” that provide for keeping such information confidential.
The General Manager is the designated Information Security Program Officer for Suncoast Tarpon Shoot-out.
Specific customer confidential information gathered by Suncoast Tarpon Shoot-out employees or representatives for the purpose of sales is retained by the General Manager.
Physical documentation (completed forms, copies of documents, paper forms) retained by Suncoast Tarpon Shoot-out are kept in organized files in locked filing cabinets that are not in common areas or in a general pathway. Digitally stored information is maintained in password-coded computers, on which the passwords are changed regularly and known only to authorized personnel. These computers contain a lock-out feature and timer for extra precautionary measures.
When the time of use for specifically identifiable private customer information is passed, it is deleted from digital files and paper files are shredded before disposal.
The Security Information Officer is responsible for testing, evaluating effectiveness, and adjusting our program to maintain the highest security for our customer’s information.
Risks to the security, confidentiality and integrity of customer information are assessed regularly by the Information Security Program Officer. Employees are trained as to the proper handling procedures of confidential customer information by their department managers, who have been trained by the Information Security Program Officer.
Vendors and providers of service to Suncoast Tarpon Shoot-out and Suncoast Tarpon Shoot-out customers are capable of maintaining appropriate safeguards for customer information passed on to them by Suncoast Tarpon Shoot-out for the purpose of servicing our clients.
Suncoast Tarpon Shoot-out has the highest respect for our customer’s privacy and will maintain complete voluntary compliance with the Graham-Leach-Bliley Act and the FTC’s interpretation, the Information Safeguarding Rule.