Facilities Security Policy

STATEMENT OF POLICY

To protect Company employees and provide security for all data and property entrusted to the Company’s care custody and control.

GENERAL

Company facilities including office, collateral storage area, personal property storage area, and records retention area shall be restricted.

Access to any restricted area requires visitor identification and sign in.

Any unrecognized person in a restricted area should be challenged as to their right to be there.

OFFICE FACILITY

The door to the restricted office area shall remain locked at all times.

All computer screens should be positioned to avoid viewing by any unauthorized party including visitors, debtors, transporters, etc.

Handling and storage of files shall comply with the Company’s Clean Desk Clean Screen Policy

SECURED VEHICLE STORAGE

Secured Vehicle Storage area must be kept clean and organized.

Perimeter fencing must be inspected for damage on a regular basis.

All damage to perimeter fencing should be immediately reported to the Company Owner or Office Manager.

Gates to the all Secured Vehicle Storage areas shall remain locked at all times when not in use for immediate ingress or egress.

SECURED KEY AND KEY EQUIPMENT STORAGE

Keys shall be removed from all repossessed vehicles.

All repossessed collateral keys shall be properly identified and stored in a locked container inside lockable room inside a restricted area.

All key making equipment shall be stored inside a restricted area in a lockable room.

All repossession entry tools, lockout kits, wedges, rods, etc shall be kept in a restricted area inside a lockable room or inside a locked recovery vehicle.

SECURED PERSONAL PROPERTY STORAGE

All personal property located in or on a repossessed vehicle that can be removed without the use of a tool shall be inventoried and removed from the repossessed vehicle.

All personal property that would require the use of a tool should be photographed and notated on the condition report.

Any Non-Public Personal Information located inside the repossessed vehicle should be placed in a container.

All personal property including any Non-Public Personal Information container shall be containerized (boxes, bags, etc.) and labeled to insure easy access and to differentiate it from other personal property.

The properly identified containers shall be stored inside the Secured locked Personal Property Storage area.

If the owner of the personal property does not reclaim the personal property prior to its disposition the container of Non-Public Personal Property should be removed and its contents should be disposed of in compliance with the Company’s Non-public Personal Information Compliance Policy.

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4. Facilities Security Policy