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Performing due diligence on all data and security protocols when selecting and monitoring vendors;
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Developing privacy provisions for contracts with TPAs and other service providers over and above standard confidentiality agreements;
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Limiting access to sensitive information to necessary personnel;
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Training personnel on the law and the fiduciary responsibilities;
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Developing written policies and procedures detailing for personnel the applicable state and federal laws;
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Continuing to monitor and watch over service providers with access to sensitive data.
National Law Review | Jackson Lewis P.C. | Employee Benefit Plans and Data Security Issues