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III. Administrative Requirements for HIPAA Implementation <br />A. Overview <br />The Privacy Rules require that a Business Associate have in place appropriate <br />administrative safeguards to protect the privacy of Personally -Identifiable Information. <br />B. Purpose <br />To provide instructions regarding Virtru's obligations relating to the implementation of <br />administrative requirements of the Privacy Rules. <br />C. Applicability <br />This policy applies to all Virtru employees, which is defined for the purposes of this <br />document to be employees of all current and future subsidiaries of Virtru. <br />D. Policy <br />1. Personnel Designations: Virtru has designated and documented designations <br />of the following: <br />a. Will Ackerly has been designated as the Privacy Officer. <br />1) He is responsible for the development and implementation of <br />corporate -wide policies and procedures relating to the safeguarding of <br />Personally -Identifiable Information. <br />2) He will also be responsible for receiving complaints relating to <br />Personally -Identifiable Information and for providing information about <br />the Company's privacy practices. <br />b. Persons with access to Personally -Identifiable Information are listed by title <br />and department including a listing of individuals' names on the Risk <br />Assessment; and will be updated if Virtru makes any major changes to <br />processes, staff, programming or company location; or at a minimum <br />annually. Virtru will retain the previous listing for a period of not less than <br />six (6) years. <br />2. Training Requirements: Virtru shall document the following training actions: <br />All Virtru employees shall receive training on applicable policies and procedures <br />relating to Personally -Identifiable Information as necessary and appropriate for <br />such persons to carry out their functions within the Company. <br />a. Each new employee shall receive the training as described above within 30 <br />days after joining Virtru. <br />M <br />Rev.2015.8.25 <br />