The Title Insurance Team LLLP d/b/a TitleTeam is committed to safeguarding the non-public personal information (“NPI”) entrusted to us by our clients and consumers. We manage NPI in accordance with the rules set forth by the Federal Trade Commission, The Gramm-Leach Bliley Act and under the direction of the American Land Title Association Best Practices initiatives as well as through our own internal policies and procedures.
A copy of this policy may be provided to any client upon request and is available on our website at www.TitleTeamFL.com.
What is non-public personal information (NPI)?
NPI may include information about an identifiable individual which is otherwise not available to the public. This may include an individual’s name, home address, phone number, age, sex, marital status, social security number, financial information, account numbers, educational history and driver’s licenses.
What NPI do we collect?
In the normal course of providing title insurance services, we may collect certain consumer NPI, provided to us by our clients or with their consent including but not limited to:
- Social security numbers
- Loan numbers
- Driver’s license numbers
- Tax returns
- Home address
- Telephone number & Telephone number
- Bank Account Numbers
- Work address, company name, phone number
We normally collect the above information directly from consumers. We may collect information from other persons with consent or as authorized by law.
We inform consumers and/ or our clients, before or at the time of collecting NPI, of the purposes for which we are collecting the information.
How do we use and disclose NPI?
We use and disclose NPI only for the purposes for which the information was collected, except as authorized by law. For example, and in the case of a mortgagee refinance, a new mortgage lender will require an amount necessary from the current mortgage holder to pay that loan off in full before issuing a new lien against the property. For the current lien holder to provide our company with the payoff, they may require us to provide the social security number of the borrower, loan number and an executed “borrower authorization”.
How do we safeguard NPI?
We make every reasonable effort to ensure that NPI is protected while in our possession; to prevent loss, misuse, disclosure or unauthorized access.
We maintain physical office safeguards including locking filing cabinets and security cameras. We maintain a paperless work flow, but in cases where paper documents are in our possession, our Clear Desk Policy requires all papers to be locked away when an employee leaves their desk for lunch or extended appointments and at the end of each work shift.
We maintain electronic safeguards including forced password resets every 60 days, password complexity requirements, auto desktop lockouts, TLS email encryption and website encryption via a SHA-2 SSL certificate.
We maintain procedural safeguards through our commitment to training, education and practice. Our Company’s Best Practices initiatives, policies and procedures are rigorously scrutinized regularly as part of our Company’s commitment to data security, management and integrity.
We only retain NPI for as long as is reasonably necessary to fulfill the purposes for which the information was collected or for legal or business purposes. We use appropriate security measures when destroying NPI including the use of lockable onsite Shred-it boxes where all paper records are disposed of and shredding those documents on a regular basis and permanently deleting electronic records from computers, servers and copiers when necessary.
Third party “memory sticks” or thumb drives are prohibited from the company’s premises.
Questions and/ or Comments
If, as a client of TitleTeam, or as a consumer utilizing our services, you have a question or concern about the collection or manner of collection, use or destruction of NPI please contact us directly:
c/o Paul M. Pantozzi II
111 N. Magnolia Ave., Suite 150
Orlando, Florida 32801