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Required Privacy Training

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Question: 
According to the Gramm-Leach-Bliley Act, is privacy training for employees required annually?
Answer: 

No. To my knowledge the topics below are the only ones with requirements and the requirement is next to the topic. "Annually" is not used as in some cases that would be insufficient and in others it could, in theory, be overkill. But annually has become the industry standard. With the emphasis on BSA and risk based issues, annually may not be sufficient based on your employees time on the job, functions and the results of monitoring and auditing.

Mandatory Training

  • BSA (12 CFR Section 21.21(c)(4) Provide training for appropriate personnel.)
  • Bank Protection Act (12 CFR Section 21.3(a)(3) Provide initial & periodic training)
  • Reg CC (12 CFR Section 229.19(f)provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee)
  • Customer Information Security (Pursuant to the Interagency Guidelines for Safeguarding Customer Information, training is required. Many banks allow for turnover and train as needed, imposing their own requirements on frequency.)



First published on BankersOnline.com 1/17/05

First published on 01/17/2005

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