Increased Record Retention
- Save all advertising, marketing, text, email, purchase orders, and sales or leasing cycle records for longer than 24 months
- Retain text messages between sales personnel and consumers
Questions to Submit to the FTC
- Will this new proposal require all dealers to go to digital record retention?
- Will it require all dealers to spend money on app-based texting software or require dealers to buy mobile communication devices for all employees or spend dollars on an app that aligns with consumer interface requirements?
- Will employees be required to sign a privacy waiver because of access to their mobile device – the FTC doesn’t have jurisdiction over employee devices. If a dealership takes this action – is it practical?
- What if a dealership changes software provider? Historical texts are saved with the previous provider. Will the FTC mandate that texts are “the dealer’s data,” and that software providers must provide them if requested? This move would provide precedence for a long-disputed conversation with DMS providers.