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NE 181st location witnessed Spruill placing documents into the dumpster. He investigated and found that the documents contained personal information including unredacted Social Security numbers. He contacted a Portland television station, which subsequently contacted the State of Oregon, Division of Finance and Corporate Securities ("DFCS"). A staff enforcement officer of DFCS contacted the television reporter at the Brooke Auto offices and recovered the discarded documents from the dumpster.


Spruill told DFCS investigators that he disposed of the records of the

various insurance businesses in the unlocked dumpster. He acknowledged that the materials included personal information, including unredacted Social Security numbers, client names, driver license numbers and credit card numbers, as well as

business banking records. He told investigators that he wanted to be in compliance with the statutes and that he understood that ignorance of the law was not an excuse.

He said that when he inquired of local police and the State of Oregon Insurance Division back in the fall of 2008, no one told him that discarding these records was wrong.


At the time he discarded the documents, Spruill had not developed

reasonable safeguards to protect the security, confidentiality and integrity of the personal information or data collected or acquired in the course of conducting his

business, including disposal of the data.


CONCLUSIONS OF LAW Brooke Auto is, at all times material herein, considered a "financial

institution" for purposes of the Gramm-Leach-Bliley Act, 15 USC § 6801, et seq.

  • (1999)


  • 11.

    Spruill is a licensee of the Insurance Division as defined by ORS 746.600,

meaning that he is an insurer, insurance producer or other person authorized or

Page 4-CEASE AND DESIST ORDER - Robert Warren Spruill (ID-09-0027)

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