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CFPB Notice

ALTA Best Practice #3   

Information Security - Keeping Secrets from the Backyard to the Board Room


We all learned how to keep a secret in the backyard as a small child - "Do not tell anyone."  If you divulged another's secret, then you were subject to their wrath.  The lessons of our youth get more complicated as we have to communicate with others for legitimate reasons and such communications have to be kept secret.  Now that we are grown up and sitting in a board room or office, we call it keeping information in confidence.  We have to exhibit that the information will not be intentionally or unintentionally released to a person with whom you do not share said confidence.  To do this, we must develop procedures and policies to keep these secrets confidential.   We must not only know how to keep a secret but we have to demonstrate that we have procedures in place to ensure that secrets are kept.