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3. New Employees: New employees shall be trained on the corporate policies and <br />procedures as part of their normal employment process and shall be trained on <br />our Privacy Policies and Procedures, if applicable, within 30 days of being <br />employed by Virtru. The Assistant ISO, Jordan Duggan, shall document this <br />training and provide the Privacy Officer with documentation of this training within <br />the 30-day period. <br />4. Transfers: When an employee transfers from one department to another, the <br />employee shall be trained on our Privacy Policies and Procedures within 30 days of <br />being assigned. Jordan Duggan shall document this training and provide the <br />Privacy Officer with documentation of this training, within the 30-day period. <br />5. Material Change in Policies and Procedures: when a material change in the policies <br />and procedures occurs, each employee shall receive training on such changes <br />within 30 days of the implementation of the change. Jordan Duggan shall document <br />this training and provide the Privacy Officer with documentation of this training, <br />within the 30-day period. <br />E. 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 />Rev.2015.8.25 <br />25 <br />