Tom Kline Ripping off the GLBA Bandaid

How long have Tom Kline from Better Vantage Point & I been screaming from the rooftops about GLBA? I was talking with a gentleman last week where I dove into the Facts Not Feelings archives. Chris Tragesz, a cyber security forensics specialist, sat down with me at the first of the year. A number of security issues are frequently addressed in dealerships, he discusses how to easily & affordably resolve them, and he dispels some myths about MFA (Multi Factor Authentication). We discussed the Gramm-Leach-Bliley Act (GLBA).

To follow up from the previous episode of “We're Gonna Need A Bigger Megaphone,” today Tom Kline & I are diving into GLBA and ripping off the Bandaid. What happens when you rip off the Bandaid? It stings at first. The pain is instantaneous, but gets better a lot quicker than a slow painful death!

This is the fifth episode we have done on Gramm-Leach-Bliley. The question is how are we going to make it different? How can we bring more value to you all? Enter Tom Kline! Tom recently gave a GLBA presentation to the NIADA National Policy Conference. Tom has 30 years of dealership ownership experience. He now excels in dealership dispute, compliance, risk mitigation, and consulting with his company Better Vantage Point. The next way to make this hit home is to simplify the talking points. I want to ensure anyone watching can easily digest anything we say. There are so many acronyms and scary terms being thrown around and we want to make this easy, breezy, Cover Girl for all!

More on Gramm-Leach-Bliley Act (GLBA): https://bit.ly/3C8qk30

The Privacy of Consumer Financial Information Rule of the Gramm-Leach-Bliley Act: https://bit.ly/3M269bw

FTC's Privacy Rule and Auto Dealers: https://bit.ly/3dXETyB

Follow Tom: https://qrco.de/bdN0mC

Let BZ Consultants Inspect What Should Be Expected: https://qrco.de/bcqqFo

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Chapters

0:00 Start

2:13 What's our mission today? Explain what GLBA is, why it's so important, the good, the bad, the ugly, & how ADF/XML forms fit into the Gramm-Leach-Bliley Act. I’m joined by Tom Kline from Better Vantage Point who lives & breathes this every day.

3:46 Quick Gramm-Leach-Bliley Act history. When is the deadline for dealers?

4:21 What is the first, biggest, and most complicated component of the GLBA in Tom’s mind? It is key to point out that all data, whether at rest or in transit must be encrypted. This leads into ADF/XML Format. All this must be encrypted. What does this mean?

5:57 Quick ADF/XML leads tutorial: how they are distributed to dealers, third party providers, OEMs, & the never ending sticky spider web of mess they cause.

7:25 Do you know that the definition of PII (Personal Identified Information) is changing? What is included now?

8:47 To reiterate the last few minutes, there is no one solution that can make you 100% GLBA compliant.

10:46 What is “First Party Data”?

12:03 What is a Compliance Management System (CMS)? Do dealerships need one? Whose responsibility is this?

15:05 What are the penalties for violating GLBA? How much are the GLBA fines?

16:20 What are the main bullet points of GLBA and FTC Privacy Rules that Dealers should be implementing right now? 1 Securing Data

16:41 2 MFA (Multi-Factor Authentication). What is MFA (Multi-Factor Authentication)? Which product does Tom recommend?

17:59 3 Education. Did you know that you need to train all of your employees? Are you having all employees sign a policy?

19:39 There are GLBA software programs on the market that will help dealers with about 30% of the heavy lifting as they handle vendor management: websites and sending data back and forth.

21:35 Phishing Tests: If management simply checks GLBA boxes, an employee may never receive the education they need. Will this truly be implemented in house? It will take a massive culture shift in some incidents.

23:46 Unless you have an audit function behind your compliance program you don’t have a compliance program.

24:51 How much insurance do I need? Do my vendor partners need insurance? How much insurance is enough insurance? What is Risk Appetite?

31:02 Customer Complaints: Are reputation management companies sufficient? What steps should dealers take to find and remedy online consumer complaints? Listen to the feedback online. Are you learning from what your consumers are saying online? Do you have one person answering reviews at each location or dumping that task on one person?

39:52 Dealers now need to audit their websites to ensure compliance with advertising laws. If there are contradicting views between DOT, OEM,& your auditor, what should the dealer do?

44:43 Lightning Round

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