" '" u
c:: ...... Q),.,oj .........
The Director FINDS that:
FINDINGS OF FACT
Robert Warren Spruill, a resident ofthe State of Washington, is an
insurance producer licensed to conduct insurance business in the State of Oregon
(License # 145167). Spruill is authorized to sell health, property, casualty and life
insurance products in Oregon. He does business under a number of assumed
business names, including Brooke Auto Insurance Services and Brooke Agency
Services Company, LLC (hereinafter "Brooke Auto"). Brooke Auto has offices located
at 1513 NE 181st Avenue, Portland, Oregon 97230.
The Oregon Consumer Identity Theft Protection Act requires persons
who own, maintain or otherwise possess data that includes a consumer's personal
information that is used in the course of the person's business, vocation, occupation
or volunteer activities to develop, implement and maintain reasonable safeguards to
protect the security, confidentiality and integrity of the personal information,
including disposal of the data.
A person that is subject to and complies with regulations promulgated
pursuant to Title V of the Financial Services Modernization Act of 1999, otherwise
known as the Gramm-Leach-Bliley Act, 15 USC § 6801, et seq., is deemed to be in
compliance with provisions of the Oregon Consumer Identity Theft Protection Act.
The Gramm-Leach-Bliley Act requires the primary regulator of financial
services providers, which for insurance producers would be the Oregon Insurance
Division, to establish appropriate standards to respect the privacy of insurance customers and to protect the security and confidentiality of those customers'
nonpublic information. In furtherance ofthis federal requirement, the Director,
pursuant to the Oregon Insurance Code, ORS Chapter 731, et seq., has adopted OAR