Non Public Information and title agents

At least once a month you probably receive one or more privacy policies from companies that you do business with. Most of us don't even bother to read these privacy policies any more because we are so used to seeing them.

Have you ever actually given any thought to just what information your service provider is trying to protect? Do you know what NPI is? Do you know how yours is being protected?

What is NPI?

Non-public Personal Information is any data or information considered to be personal in nature and not subject to public availability.

Personal information includes, but is not limited to:

• Individual names
• Social Security numbers
• Credit or debit card numbers
• State identification card numbers
• Driver's license numbers
• Dates of birth
• Health records when the disclosure of the information in question would reasonably be considered to be harmful or an invasion of privacy

If you take a moment to think about that list and then reflect back on the information you have been asked to provide to your lender when making a loan application, then you can see just how much of your non public information is out there for the taking. Did you know that your loan application is given to your title agent at closing so that the title agent can have you sign it at closing? Are you aware of the steps being taken by your title agent to protect your NPI?

ALTA (Amerian Land Title Association) and all state Land Title Associations including MLTA (Maryland Land Title Association) have been working hard to insure that all title agents are compliant with what is know as Pillar #3 of the ALTA Best Practices. Pillar # 3 specifically relates to securing your non public information.

What are the steps that we at Key Title, Inc. are taking to insure that your NPI is secure?

Non-Public areas of our office where NPI is stored
Background checks and screeening of all employees who are or will be authorized to access your NPI as a part of their job description
Secure safekeeping of all NPI in locked cabinets or secure servers upon conversion to electronic storage
Clean desk policy
Locked door policy

All title agents are required to comply with safeguarding your NPI and most are doing an excellent job of doing just that, but...

I had an opportunity to go into a title agent's office just last week and what I saw made me cringe!! The agent's office was small, but well appointed, it had a wonderful receptionist and the title agent was very knowledgeable; everyone was super friendly, but, there were stacks and stacks of files, some wide open, on desks that were visible to the public!

I realize that not every title agency has the space necessarily to afford all of their staff members a private office with a door that can be locked, but, it is imperative that all NPI be somewhere out of the reach of the public no matter the design of the office.

As part of your interview process with a prospective title agency, you may want to take a trip into their office just to see if they are protecting your NPI as though it were their own.

Please call on me for a quote for title and settlement services at 410-803-4800 or stop in to see me!! You are always welcome to come by my office at 35 Fulford Avenue, Bel Air, MD 21014 for the escorted tour and a discussion on the protection of your NPI.

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	NPI agreements for Independent Abstractors?
	I am an Independent Abstractor. I only do searches of public records. I do not do closings or keep any closing files. I have been asked by one of my clients to sign an agreement, containing all of the NPI requirements therein. Does anyone know if Independent Abstractors are required by law to sign such an agreement? Bob Newton
	by Robert Newton \| 2014/09/26 \| log in or register to post a reply

	NPI Agreements
	Bob, you are not required to sign any such agreement. And your client isn't required to send you any orders. Since your report contains bundled information which, by itself may be considered public information, the bundling of the information into a single report will cause it to be considered non-public, personal information. A number of lenders now require that their third-party vendors, as well as subcontractors (you) take reasonable steps to protect consumers' non-public information, because the lenders will now be held responsible for theft, or misuse, of their borrowers' private information, whether it is their own negligence or their vendors' negligence, or their subcontractors' negligence. Thus, your client needs to demonstrate due diligence with respect to ensuring the due diligence of their subcontractors. The number of lenders requiring documentation to ensure due diligence with information security, will increase as the lenders develop and finalize their information security policies and procedures. This will lead to increasing numbers of title agents requiring their abstractors to sign these agreements. You can refuse to sign them, but I'm pretty sure you will see your order count dwindle.
	by Patrick Scott \| 2015/10/05 \| log in or register to post a reply

	I conduct all kinds financial and business loan funding transactions
	I conduct all kinds financial and business loan funding transactions with individuals and companies across all sectors locally and internationally, we are at your service. All kinds of financial service Contact: davephilip12@gmail.com
	by Dave Philip \| 2019/03/11 \| log in or register to post a reply

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