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b. Each employee whose functions are impacted by a material change in the <br />policies and procedures relating to Personally -Identifiable Information, or <br />by a change in position or job description, shall receive the training as <br />described above within 30 days after the change becomes effective. <br />c. Complaints handled by Committee... <br />3. Safeguards: Virtru shall have in place appropriate Administrative, Technical, and <br />Physical Safeguards to reasonably safeguard Personally -Identifiable Information <br />from intentional or unintentional unauthorized receipt, use or disclosure. <br />4. Complaint process: Virtru shall have in place a process for individuals to make <br />complaints about the Company's HIPAA Policies and Procedures and/or Virtru's <br />compliance with those Policies and Procedures, and shall document all complaints <br />received and the disposition of each complaint. (See Complaint Process) <br />5. Sanctions: Our Privacy Policies call for our workforce that has access to <br />Personally -Identifiable Information to perform certain duties and to refrain from <br />certain actions. Failure to do so will be sanctioned according to the policy below. <br />These sanctions apply to the designated workforce members including managers, <br />supervisors, and staff who have access to Personally -Identifiable Information. <br />It is intended as guidance for our business management in sanctioning information <br />security policy infractions. We reserve the right to implement sanctions differently if, <br />in our judgment, the situation warrants it. <br />We define a serious infraction as one that results in known significant damage or <br />that threatens imminent significant damage. Other infractions are simple infractions. <br />First security infraction <br />If the infraction is: <br />a. A simple infraction, and <br />b. The first infraction in the last 3 years <br />The sanction will be retraining the workforce member on the appropriate <br />policy/procedure and placement of a written letter of reprimand in the employee <br />file. The letter will notify the person of the nature of this infraction and of sanctions <br />for future potential infractions. <br />Second security infraction or first serious infraction <br />If the infraction is: <br />a. A serious infraction, or <br />Q <br />Rev.2015.8.25 <br />