FTC Safeguards Rule Update

We have shipped a few new updates to help dealers be compliant with the FTC Safeguards Rule that is going in to effect December 9, 2022.

Data Retention

On December 5, 2022, Approve Owl will delete all consumer profiles that are older than 24 months. Then, on a weekly basis, we will prune data older than 24 months. This is a dramatic change from our previous data retention policy, but it is required to stay compliant with the new rules.

If federal or state regulation requires you to keep customer data longer than 24 months, please download the consumer data in Approve Owl as a document packet for storage in your DMS or other storage system that has an appropriate retention policy.

Data Masking

On December 5, 2022, Approve Owl will mask part of the phone numbers in the Applicants list views. You will still be able to search by phone number and view the full phone number within an individual applicant's profile, but we are masking personal identifiable data in bulk lists views.

Audit Trails

Approve Owl has activity lists for applicants and users, however these lists only include entries for data creation and data manipulation.

On December 5th, Approve Owl will be have a new audit list (separate from activity lists) for viewing applicant data. We will long every applicant a user has viewed during a day in a separate lists so you can maintain compliance.

Enhanced Security

Approve Owl has always encrypted data at rest and in transit, and we have firewalls, EDR software and other safeguards in place to protect consumer data. It's why our banking and identity partners trust us to fetch and store consumer data.

We have implemented additional layers of security, and from time to time, you might be challenged when accessing the dealership portal by a CAPTCHA before accessing data.