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2. The name of the company, the person contacted, the date and time shall be <br />recorded as well as any comments made by the person receiving such calls. <br />3. The cause of the inappropriate disclosure shall be determined and reported to the <br />Virtru Privacy Officer. <br />Methods to prevent a reoccurrence of the inappropriate disclosure shall be formulated <br />and put into place. Any additional actions prescribed by regulations shall be performed to <br />the extent possible. <br />G. Enforcement <br />Any employee found to have violated this policy shall be subject to disciplinary action, up <br />to and including termination of employment. In the case where inappropriate access, use <br />or disclosure of Personally -Identifiable Information was or may have been involved, such <br />individuals may additionally be reported to the appropriate enforcement agencies. <br />XI. Training Policy <br />A. Overview <br />The Privacy Rules require that Virtru train their employees on the requirements of our <br />Privacy Policies and Procedures developed to protect the Personally -Identifiable <br />Information to which employees are provided access. The Company has determined that <br />all employees of Virtru shall be trained on Privacy so that we can provide the necessary <br />assurances for the protection of Personally -Identifiable Information to our clients, <br />vendors and business partners as required under the Privacy Rules. <br />B. Purpose: <br />To provide instructions to all Virtru employees regarding the requirement for HIPAA <br />training. <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. General: It is the policy of the Company that all employees of Virtru and its <br />current and future subsidiaries be trained on Privacy and the Company policies <br />and procedures created to protect Personally -Identifiable Information. <br />2. Duty Specific Training: Privacy training shall be appropriate to the tasks that each <br />employee performs. In the case where an employee does not come into contact <br />with Personally -Identifiable Information as a normal course of the employee's <br />duties, the employee shall be trained on the corporate policies and procedures. <br />Rev.2015.8.25 <br />24 <br />