In 2018, HB 18-1128 was passed to strengthen protections for consumer data privacy, which required any entity maintaining personal identifying information (“PII”) to adopt a written policy setting forth a process for the security and destruction of paper and electronic documents containing personal identifying information. Personal identifying information includes, but is not limited to, social security numbers, drivers license numbers, passport numbers, and the like.

Now that the Corporate Transparency Act (“CTA”) is in effect, board members will be required to provide copies of the their drivers licenses, state ID’s, and/or passports to their associations so they may be registered as beneficial owners with Financial Crimes Enforcement Network (“FinCEN”). Because these documents constitute personal identifying information, associations should strongly consider adopting PII policies to be compliant with Colorado law and to have a process in place for protecting the personal identifying information.

Please contact an Altitude attorney, at 303.432.9999 or at [email protected] with questions about adopting a PII policy for your community.

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