As of September 2018 covered entity (including property managers, brokerage firms and brokers) have new strict liability for security breaches dealing with personal identifying information. Personal Identifying information such as social security numbers, drivers license numbers, passwords and financial accounts.
Real Estate brokers must ensure that third-party service providers like on-line or cloud based accounting & management software have policies in place as well.
At the Colorado Real Estate Commission meeting on December 4, 2018, the Commission revised and adopted a new Commission Position on Office Policy Manuals in response to the passage of HB18-1128 (Protections for Consumer Data Privacy).
Below are links to both the revised CP-21 and the House Bill. Please review these new recommendations for consideration and revisions to your Office Policy Manuals.