or insurance consultant who violates any provision of the Insurance Code, including
any lawful rule adopted by the Director, may be subject to a civil penalty of not more
than $1,000 for each offense.
THE DIRECfOR ISSUES THE FOLLOWING ORDERS: Cease and Desist Orders
Pursuant to ORS 646A.624(3), Robert Warren Spruill is ORDERED to
CEASE AND DESIST from violating the requirements of the Oregon Consumer
Identity Theft Protection Act requiring him to develop, implement and maintain
reasonable safeguards to protect the security, confidentiality and integrity of personal information, including disposal of the data.
Pursuant to ORS 731.252(1), Robert Warren Spruill is ORDERED to
CEASE AND DESIST from violating the requirements of the Oregon Insurance
Code and standards adopted pursuant to the Gramm-Leach-Bliley Act that require him to adopt and implement a comprehensive written information security program
that includes administrative, technical and physical safeguards for the protection of
Destruction of Other Business Records
In the event that he has in his possession a collection of business
documents to be discarded that contain personal information, including but not
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