1.0 Overview

a. The purpose for this policy is to establish a culture of security and trust for all employees at Great American Title Company. An effective clean desk effort involving the participation and support of all Great American Title Company employees can greatly protect paper documents that contain sensitive information about our clients, customers and vendors. All employees should familiarize themselves with the guidelines of this policy.

2.0 Purpose

The main reasons for a clean desk policy are:

∙A clean desk can produce a positive image when our customers visit the company.

∙It reduces the threat of a security incident as confidential information will be locked away when unattended.

∙Sensitive documents left in the open can be stolen by a malicious entity.

3.0Responsibility

All staff, employees and entities working on behalf of are subject to this policy

4.0 Scope

At known extended periods away from your desk, such as a lunch break, sensitive working papers are expected to be placed in a locked and secured area.

At the end of each work day, each employee is expected to tidy their desk and put away all office papers and/or Guaranty Files in desk drawers and/or filing cabinets.

5.0 Action

All Applicable Parties must:

(1)Close paper and/or electronic files containing NPI when they are away from their desk.

(2)Log-off or lock their computers when unattended.

(3)Enable a password-protected screen saver.

(4)At the end of each working day, safeguard all documents, files, portable devices, and electronic media containing NPI in a locked desk, file cabinet, or secure location.

(5)Store materials (e.g. day planners) with NPI in a locked drawer or take them when away from desk for extended periods of time, including overnight.

(6)Secure all keys used to access NPI.

(7)Remove all documents from copy and facsimile containing NPI

(8)Secure passwords at all times.

6.0 Enforcement

This policy will be enforced by the Manager and/or Executive Team. Violations may result in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. Where illegal activities or theft of company property (physical or intellectual) are suspected, the company may report such activities to the applicable authorities.

7.0 Revision History

Revision 1.0, 11/01/2012

Revision 2.0, 09/01/2014