Auto dealerships collect some of the most sensitive consumer information in the retail space. With high-value transactions and detailed financial data, dealers face significant obligations to protect that information. A wide range of laws and regulations govern how dealers must collect, share, process, and safeguard consumer information, including:

privacy and safeguards team auto dealer (1)

The Gramm-Leach-Bliley Act
The FTC Safeguards Rule
The FTC Red Flags Rule
The Financial Privacy Rule
The FTC Disposal Rule
Various state privacy laws

The consequences of non-compliance are severe. A violation can be considered an unfair and deceptive practice under Section 5 of the FTC Act, carrying penalties exceeding $55,000 per violation. When regulators stack multiple violations together, dealers can quickly face multi-million-dollar fines.

With so much at stake, where should dealers begin? The foundation of privacy and safeguards compliance starts with building the right team.

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Building Your Privacy and Safeguards Team

Establishing a dedicated Privacy and Safeguards team is the first critical step in achieving compliance. This team will implement, oversee, and enforce your written information security program and privacy initiatives.

At minimum, your team should include:

Privacy Officer/Qualified Individual

This person will:

Implement your written information security program
Oversee compliance efforts
Enforce policies and procedures

The Safeguards Rule, which applies to all dealerships involved in financing, requires this role. The qualified individual doesn’t need specific credentials, but they must be technically savvy enough to understand privacy laws and the Safeguards Rule requirements and be capable of implementing them effectively.

Qualified Information Security Personnel

The Safeguards Rule also requires qualified information security personnel to:

Help manage information security risks
Oversee the information security program

This can be your in-house IT person or a managed service provider with information security expertise.

Additional Team Members

Best practices suggest including:

Department representatives (particularly from areas handling sensitive information)
Compliance officer or legal counsel (if available)
External compliance provider representative (if working with a company like KPA)

Team Responsibilities

Your Privacy and Safeguards team should meet regularly to:

Discuss the information security program
Clarify roles and responsibilities
Identify emerging risks or compliance gaps
Plan improvements to policies and procedures
Address any security incidents
Document meeting outcomes and action items

The team structure provides accountability and ensures that privacy and information security remain organizational priorities, not just IT concerns.

How KPA Helps Your Privacy and Safeguards Team

While KPA can’t replace your internal Privacy and Safeguards team—your team must include your own people—we provide the guidance and expertise to help your team succeed.

Our specialized consultants help you:

Define appropriate team roles and responsibilities
Establish effective meeting cadences
Develop a roadmap for program implementation
Provide industry-specific training for team members
Guide your qualified individual through their responsibilities
Offer ongoing support as regulations evolve

With KPA as your compliance partner, your privacy and safeguards team won’t have to figure everything out independently. We’ve helped thousands of dealerships establish and maintain effective compliance teams that protect customer information and minimize regulatory risk.

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Join us as we break down the essential steps every dealership must take to build and maintain a successful privacy and safeguards program. If you haven’t already, subscribe to our blog for weekly installments of the 10 steps to complete compliance.