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,

Director assesses Robert Warren Spruill a total CIVIL PENALTY of $11,000 (eleven thousand dollars) as detailed below:

a.

Pursuant to ORS 646A.624(4) and ORS 731.988, the Director assesses

Robert Warren Spruill a CIVIL PENALTY of $1,000 (one thousand dollars) for failure to develop a comprehensive written information security plan with reasonable

safeguards to protect the security, confidentiality and integrity of the personal information he collected or acquired in the course of conducting his business, including disposal ofthe data, as required by ORS 646A.622(1) and OAR 836-081

0111(1).

b.

Pursuant to ORS 646A.624(4) and 731.988, the Director assesses

Robert Warren Spruill a CIVIL PENALTY of $10,000 (ten thousand dollars) for

discarding over 1,000 insurance business documents in violation ofORS 646A.622(1)

and OAR 836-081-0111(1).

c.

Collection of $8,500 (eight thousand five hundred dollars) ofthe

assessed CIVIL PENALTY is suspended by the Director so long as Respondent

Robert W. Spruill is in full compliance with the terms and conditions of this Consent Order; PROVIDED HOWEVER, that any unpaid portion of the assessed penalty, including the suspended portion of the penalty, will be immediately due and payable upon a determination by the Director that Respondent Robert W. Spruill has violated

any term of this Order, or any provision of the Consumer Identity Theft Protection Act, ORS Chapter 646A, or OAR Chapter 836, Division 081.

22.

The unsuspended portion of the assessed CIVIL PENALTY in the

amount of $2,500 (two thousand five hundred dollars) must be remitted to the

Department of Consumer and Business Services according to the payment schedule

outlined below. Failure to timely pay the CIVIL PENALTY is a violation of this Order.

Page 7-CEASE AND DESIST ORDER - Robert Warren Spruill (ID-09-0027)

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