HL Hunt Data Management and Compliance Policies & Procedures

HL Hunt | Data Management & Compliance Policies

Preamble & Scope of Application

This document establishes the comprehensive framework governing all data management operations, compliance protocols, and quality assurance measures implemented by HL Hunt ("the Company," "we," "our," or "us"). These policies apply to all employees, contractors, subsidiaries, affiliates, and third-party service providers who access, process, store, or transmit Company data.

The provisions herein ensure the highest standards of data integrity, regulatory compliance, operational excellence, and consumer protection in accordance with applicable federal, state, and international laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Consumer Privacy Act (CCPA), and the General Data Protection Regulation (GDPR).

Non-compliance with these policies may result in disciplinary action, up to and including termination of employment or contract, and may expose the Company and/or the individual to civil and criminal liability.

1. Standard Procedures for Data Compilation and Contribution

HL Hunt maintains rigorous standards for the compilation, contribution, and integration of data across all enterprise systems to ensure accuracy, traceability, and compliance.

1.1 Source Verification Requirements

All data sources, whether internal or external, shall undergo comprehensive verification procedures prior to entry into Company databases.
Verification shall include authentication of source provenance, validation of data accuracy against authoritative records, and assessment of timeliness and relevance.
Documentation of verification activities shall be maintained in accordance with the record retention policy and made available for audit upon request.

1.2 Documentation & Formatting Standards

All personnel contributing data shall adhere to established formatting specifications, metadata requirements, and documentation standards as defined in the Enterprise Data Dictionary.
Data contributions shall include complete attribution: source identification, collection methodology, date of acquisition, and any known limitations.
Deviations from standard formats require prior written approval from the Data Governance Committee.

1.3 Two-Stage Verification Protocol

All data collection and contribution activities shall be subject to a mandatory two-stage verification process incorporating both automated validation and manual quality assurance review.
Stage One (Automated): Data shall pass through validation engines checking format compliance, referential integrity, business rule adherence, and anomaly detection.
Stage Two (Manual): Data shall be reviewed by qualified personnel who verify accuracy, completeness, and appropriateness for intended purpose.
Data failing either stage shall be quarantined pending remediation.

1.4 Audit Trail & Accountability

All data contributions shall be logged with immutable timestamps, unique transaction identifiers, and contributor identification.
Audit logs shall capture: user identification, timestamp (UTC), data elements modified, nature of modification, system utilized, and approval authorization.
Audit records shall be retained for a minimum of seven (7) years.

External Data Source Authorization

Any external data source proposed for integration must receive pre-approval from the Data Governance Committee following due diligence assessment, security review, and quality evaluation. Unauthorized integration constitutes a serious policy violation.

2. Internal Controls for Accuracy and Integrity of Information

HL Hunt implements a comprehensive framework of internal controls to prevent, detect, and remediate data quality issues throughout the data lifecycle.

2.1 Automated Validation Framework

Automated data validation systems continuously monitor data flows for errors, inconsistencies, anomalies, and deviations from established business rules.
Validation rules shall be documented, version-controlled, and reviewed quarterly by the Data Quality Team.
Validation exceptions shall trigger automated alerts to designated data stewards for investigation.

2.2 Internal Audit Program

The Internal Audit Department shall conduct regular reviews of data integrity controls, including reconciliation checks, completeness assessments, and accuracy testing.
Audit frequency shall be based on risk assessment, with high-risk categories reviewed monthly and standard categories quarterly.
Audit findings shall be reported to the Audit Committee and Chief Compliance Officer with remediation plans.

2.3 Discrepancy Management Protocol

All identified discrepancies shall be reported immediately through the Enterprise Incident Management System.
Discrepancies classified by severity with remediation timeframes: Critical (4 hours), High (24 hours), Medium (72 hours), Low (5 business days).
Root cause analysis shall be performed for Critical and High severity discrepancies.

2.4 Training & Certification

All employees with access to sensitive data shall complete mandatory data integrity training upon hiring and annual recertification.
Training shall cover data handling procedures, quality standards, regulatory requirements, security protocols, and incident reporting.
Training completion shall be documented and verified prior to granting data access privileges.

2.5 Access Control Framework

Access controls based on the principle of least privilege ensure personnel access only data necessary for their responsibilities.
Access privileges reviewed quarterly by department managers and validated against current job responsibilities.
Data modifications require appropriate authorization; elevated privileges require multi-factor authentication and supervisory approval.
Unauthorized access attempts shall be logged, investigated, and reported to the Chief Information Security Officer within 24 hours.

3. Policies and Processes for Data Modification and Deletion

HL Hunt maintains clear guidelines for all data modification, correction, and deletion activities to ensure regulatory compliance and protect data subject rights.

3.1 Data Update & Correction Procedures

Requests for data updates or corrections shall be submitted through the Data Modification Request System with supporting documentation.
Updates to critical data elements require dual authorization from requesting department manager and Data Governance Team.
Original values shall be preserved in the audit trail with modification reason, authorizing personnel, and timestamp.
Batch updates affecting more than 100 records require pre-implementation and post-implementation review.

3.2 Stakeholder Correction Request Process

Internal and external stakeholders may submit correction requests through designated channels including Customer Service Portal, written correspondence, or regulatory dispute processes.
Correction requests shall be acknowledged within two (2) business days and investigated within thirty (30) calendar days.
Requestors shall be notified in writing of outcomes, including explanation of any denial and appeal procedures.

3.3 Data Deletion Protocol

Deletion requests shall be reviewed by the Compliance Department to ensure adherence to regulatory retention requirements and legal hold obligations.
Deletion requests conflicting with retention requirements shall be documented with denial reason and communicated to requestor.
Approved deletions shall be executed per Secure Data Destruction Standard with cryptographic verification of complete deletion.

3.4 Secure Archival Procedures

Data marked for deletion shall first be transferred to secure archival storage for the period specified in the Record Retention Schedule.
Archived data shall be encrypted using AES-256 and stored in access-restricted repositories with audit logging.
Upon retention period expiration, archived data shall be permanently destroyed using certified methods with destruction certificates retained.

4. Processes to Prevent Duplicative Reporting

HL Hunt implements comprehensive controls to minimize redundant data entry and duplicative reporting.

4.1 Centralized Data Repository

The Company maintains a centralized Enterprise Data Warehouse as the authoritative source for all reporting and analytical activities.
Departmental data marts shall be synchronized with the central repository through automated ETL processes with reconciliation validation.
Creation of unauthorized data stores is prohibited without explicit approval from the Chief Data Officer.

4.2 Unique Identification Schema

All data entries assigned globally unique identifiers (GUIDs) at creation, enabling reliable tracking and deduplication.
Identifier schema incorporates checksums and validation algorithms to prevent duplicate assignments.
Entity resolution processes utilize unique identifiers supplemented by matching algorithms.

4.3 Duplicate Detection Systems

Automated duplicate detection monitors data ingestion in real-time, flagging potential duplicates for review prior to database commitment.
Detection algorithms employ fuzzy matching, phonetic comparison, and machine learning to identify probable duplicates.
Flagged duplicates routed to data stewards for investigation and resolution.

4.4 Cross-Reference Validation

Periodic cross-checks reconcile reported data against existing records to identify duplicative reporting or inconsistencies.
Cross-reference validation performed monthly for high-frequency reporting and quarterly for standard cycles.
Identified duplicates remediated per Data Correction Protocol with root causes addressed.

5. Established Internal Controls for Data Quality and Integrity

HL Hunt implements a comprehensive quality assurance framework incorporating proactive monitoring, systematic assessment, and continuous improvement.

5.1 Statistical Sampling Program

Random statistical sampling of data entries performed continuously to assess accuracy, completeness, and quality conformance.
Sample sizes determined using accepted statistical methodologies to achieve 95% confidence with margin of error not exceeding 3%.
Sampling results documented, analyzed for trends, and reported monthly to the Data Governance Committee.

5.2 Internal Audit Schedule

Comprehensive internal audits conducted monthly examining policy adherence, control effectiveness, and data accuracy.
Audit scope rotates to ensure complete coverage of all data domains annually with risk-based prioritization.
Audit reports presented to Audit Committee within fifteen (15) business days with management responses.

5.3 Issue Escalation Framework

Formal escalation framework governs reporting and resolution of data quality concerns with defined paths based on severity.
Critical issues affecting regulatory reporting or consumer data escalated immediately to Chief Compliance Officer and Chief Data Officer.
Escalated issues tracked until resolution with status updates to affected stakeholders.

5.4 Continuous Improvement

Quality control measures reviewed and updated periodically based on industry best practices and regulatory developments.
Annual benchmarking conducted against industry standards to identify improvement opportunities.
Process improvement initiatives documented, prioritized, and tracked through the Project Management Office.

6. Oversight of Third-Party Data Providers

HL Hunt enforces comprehensive oversight mechanisms for all third-party data providers to ensure consistent quality and regulatory compliance.

6.1 Vendor Vetting & Onboarding

Prospective data providers undergo comprehensive vetting including evaluation of data integrity policies, security controls, compliance history, and financial stability.
Vetting includes review of provider certifications (SOC 2, ISO 27001), independent audit reports, and client references.
Providers handling consumer data must demonstrate regulatory compliance and appropriate liability insurance coverage.

6.2 Continuous Performance Monitoring

Data providers subject to continuous monitoring against contractual SLAs and quality benchmarks.
Monitoring metrics include data accuracy rates, delivery timeliness, issue resolution responsiveness, and specification compliance.
Performance dashboards maintained and reviewed monthly by Vendor Management Team.

6.3 Periodic Audit Requirements

Periodic audits of provider operations conducted to ensure ongoing compliance with standards and obligations.
Audit frequency by risk classification: Critical (annually), High-risk (18 months), Standard (24 months).
Audit findings communicated with required remediation timelines and verified through follow-up assessment.

6.4 Non-Compliance Remediation

Providers failing to meet standards subject to formal corrective action including remediation plans with defined milestones.
Repeated or severe non-compliance may result in enhanced oversight, financial penalties, or relationship termination.
Termination procedures ensure orderly transition with minimal business disruption.

7. Policies and Procedures for Review and Evaluation of Data Providers

HL Hunt maintains rigorous review and evaluation procedures to ensure providers consistently meet quality, compliance, and service standards.

7.1 Annual Performance Evaluation

All data providers undergo formal annual evaluations assessing accuracy, timeliness, responsiveness, and regulatory compliance.
Evaluations incorporate quantitative metrics and qualitative assessments from business unit stakeholders.
Results documented and communicated with recognition for exceptional performance or improvement plans.

7.2 Provider Scorecard System

Comprehensive scoring evaluates providers across dimensions of accuracy, timeliness, compliance, service, and value.
Scorecard weightings reflect business priorities with regulatory compliance and data accuracy receiving highest emphasis.
Aggregate scores inform vendor tiering, contract renewal decisions, and business volume allocation.

Performance Tier	Score Range	Contract Status	Review Frequency
Preferred Partner	90–100	Eligible for extension	Annual
Approved Provider	75–89	Standard renewal	Semi-annual
Conditional Status	60–74	Improvement required	Quarterly
Under Review	Below 60	Termination consideration	Monthly

7.3 Security & Ethics Standards

Providers must adhere to HL Hunt's data security standards including encryption, access controls, incident response, and breach notification.
Providers shall comply with the Ethical Data Use Policy prohibiting discriminatory practices, unauthorized sharing, or harmful data use.
Compliance verified through contractual representations, audit rights, and ongoing monitoring.

8. Best Practices Regarding Consumer Impact

HL Hunt prioritizes consumer protection and data privacy, implementing comprehensive safeguards to ensure responsible data stewardship.

8.1 Transparency Standards

Transparent, clearly written policies regarding collection, use, storage, and disclosure of consumer data made available through privacy notices.
Privacy notices written in plain language, clearly explaining consumer rights and how to exercise them.
Material changes to privacy practices communicated with reasonable advance notice.

8.2 Consent Management

Consumer notification and consent mechanisms implemented per legal requirements and industry best practices.
Affirmative consent (opt-in) obtained for sensitive data categories and unexpected uses.
Accessible mechanisms provided for consent withdrawal, honored promptly and documented.

8.3 Consumer Dispute Resolution

Comprehensive dispute resolution process allows consumers to challenge data accuracy, completeness, or appropriateness.
Dispute intake available through multiple channels with accessibility accommodations.
Disputes investigated within regulatory timeframes with consumers notified of outcomes and escalation rights.

8.4 Data Security Safeguards

Consumer information protected through encryption protocols (TLS 1.3 in transit, AES-256 at rest) and comprehensive security measures.
Security architecture incorporates defense-in-depth: network segmentation, intrusion detection, endpoint protection, and SIEM.
Security measures assessed annually by independent third parties with findings addressed through remediation.

8.5 Regulatory Compliance

Compliance maintained with applicable laws including FCRA, GLBA, CCPA/CPRA, GDPR, and state privacy regulations.
Regulatory developments monitored continuously with compliance programs updated as necessary.
Consumer complaints filed with regulatory agencies tracked, investigated, and responded to within mandated timeframes.

9. Compliance with Fair Credit Reporting Act (FCRA)

HL Hunt strictly adheres to the Fair Credit Reporting Act, maintaining comprehensive compliance programs to protect consumer rights and ensure lawful credit reporting practices.

9.1 Data Collection & Usage Standards

All consumer credit data collected, stored, processed, and disclosed in strict accordance with FCRA requirements and FTC/CFPB guidance.
Permissible purpose verification performed prior to any consumer report disclosure with documentation retained.
Data furnishing activities comply with accuracy and dispute resolution requirements.

9.2 Consumer Access Rights

Consumers granted access to information maintained about them per FCRA disclosure requirements including free annual disclosures.
Identity verification procedures protect against unauthorized access while minimizing burden on consumers.
Disclosures include all required information: sources, recipients, and adverse action triggers.

9.3 Dispute Investigation Procedures

Consumers may dispute accuracy of information, with disputes investigated and resolved within FCRA mandated timeframes (generally 30 days).
Investigations include review of consumer-provided information, furnisher verification, and documentation of steps and conclusions.
Consumers notified of results within five (5) business days including right to add dispute statement.

9.4 Compliance Infrastructure

Dedicated FCRA Compliance team reporting to Chief Compliance Officer monitors adherence and coordinates examinations.
Compliance monitoring includes transaction testing, complaint analysis, and periodic risk assessments.
Compliance metrics reported quarterly to Board of Directors and Audit Committee.

9.5 Employee Training

Employees handling consumer credit data receive comprehensive initial FCRA training and annual recertification.
Training covers permissible purposes, consumer rights, dispute handling, adverse action requirements, and retention obligations.
Training completion documented and verified prior to granting access to consumer report information.

10. Record Retention Policy and Identified Retention Timeframes

HL Hunt enforces a structured record retention policy governing the retention, archival, and disposition of all business records.

10.1 Category-Based Retention Framework

Data categories assigned specific retention periods based on regulatory requirements, legal obligations, and business needs.
Retention periods reviewed annually by Retention Committee comprising Legal, Compliance, IT, and business representatives.
Retention schedule changes documented with rationale and communicated to affected personnel.

Record Category	Retention Period	Governing Requirement
Consumer Credit Data	7 Years	FCRA § 605
Financial Records & Transactions	10 Years	SOX, IRS Regulations
Employment Records	7 Years Post-Termination	EEOC, DOL Requirements
Contract Documentation	10 Years Post-Expiration	Statute of Limitations
Audit Trails & Logs	7 Years	Regulatory Examination
Correspondence	5 Years	Business Requirements
Litigation Hold Materials	Duration + 3 Years	Legal Preservation

10.2 Consumer Data Retention

Consumer-related data retained minimum seven (7) years per FCRA requirements for dispute resolution and regulatory examination.
Certain data elements may be retained longer when required by state laws or contractual obligations.
Upon retention expiration, consumer data securely destroyed unless subject to legal hold.

10.3 Financial Record Retention

Financial records including transactions, ledger entries, and tax documentation retained minimum ten (10) years.
Supporting documentation retained per applicable accounting standards and tax regulations.
Financial records stored in secure, access-controlled repositories with audit logging.

10.4 Secure Disposal Methods

Records exceeding retention and not subject to legal hold disposed using secure methods appropriate to sensitivity.
Physical records destroyed through cross-cut shredding by certified vendors with destruction certificates retained.
Electronic records disposed through cryptographic erasure or physical destruction per NIST SP 800-88 guidelines.

Legal Hold Protocol

When litigation is reasonably anticipated or legal process is received, the Legal Department shall issue a litigation hold notice suspending normal retention practices for potentially relevant records. All personnel shall comply with litigation holds; intentional destruction of held records may constitute spoliation of evidence with severe legal consequences.

Commitment to Excellence

By implementing these policies and procedures, HL Hunt demonstrates its commitment to data integrity, regulatory compliance, consumer protection, and operational excellence. These standards represent the foundation of our corporate responsibility and dedication to maintaining stakeholder trust.

Questions regarding these policies should be directed to the Chief Compliance Officer or the Data Governance Committee. Policy exceptions require written approval from appropriate executive authority.