--- On Wed, 12/1/10, Larry Medina <[log in to unmask]> wrote:


From: Larry Medina <[log in to unmask]>
Subject: Re: [RM] scanning checks
To: [log in to unmask]
Received: Wednesday, December 1, 2010, 8:07 AM


I'd suggest starting by checking the requirements of the GLB Act, Financial
Privacy Rule, to see if your institution is one that is impacted, then see
what you must do to comply

http://bit.ly/ik3I2r


Some things to consider though, based on your description of the issue-

Prior to this change in practices, did you photocopy checks and retain them
in physical form?

If not, why are images being kept now?

If so, do the same people have access now that had access previously?

Is there a way to limit/control access to the images to a select number of
people?

Is it possible to write the images ALL to an independent directory to
control access to them?

Can these people sign a privacy policy preventing against subsequent disclosure?

How long is the organization planning to retain the images?

You might want to ask the person who made the decision to scan and save
these images if THEY WOULD FEEL COMFORTABLE allowing a third party to have
access to this information about them and see if they understand the concern.

Larry
[log in to unmask]
[Yes, it's really me =) ]

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