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III

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or insurance consultant who violates any provision of the Insurance Code, including

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any lawful rule adopted by the Director, may be subject to a civil penalty of not more

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than $1,000 for each offense.

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ORDER

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THE DIRECfOR ISSUES THE FOLLOWING ORDERS: Cease and Desist Orders

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18.

Pursuant to ORS 646A.624(3), Robert Warren Spruill is ORDERED to

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CEASE AND DESIST from violating the requirements of the Oregon Consumer

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Identity Theft Protection Act requiring him to develop, implement and maintain

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reasonable safeguards to protect the security, confidentiality and integrity of personal information, including disposal of the data.

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19.

Pursuant to ORS 731.252(1), Robert Warren Spruill is ORDERED to

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CEASE AND DESIST from violating the requirements of the Oregon Insurance

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Code and standards adopted pursuant to the Gramm-Leach-Bliley Act that require him to adopt and implement a comprehensive written information security program

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that includes administrative, technical and physical safeguards for the protection of

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customer information.

Destruction of Other Business Records

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In the event that he has in his possession a collection of business

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documents to be discarded that contain personal information, including but not

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limited to records relating to clients, prospective clients, employees or former

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employees, and the documents to be discarded number more than 2,500 pieces of paper, Robert Warren Spruill agrees to employ a commercial document shredding service to destroy such documents.

Order Assessing Civil Penalty

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21.

Pursuant to the authority of ORS 646A.624(4) and ORS 731.988, the

Page 6-CEASE AND DESIST ORDER - Robert Warren Spruill (ID-09-0027)

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