(A) Definition of sensitive information. SENSITIVE INFORMATION includes the following items whether stored in electronic or printed format:
(1) Credit card information, including any of the following:
(a) Credit card number (in part or whole);
(b) Credit card expiration date;
(c) Cardholder name; and
(d) Cardholder address.
(2) Tax identification numbers, including:
(a) Social Security number;
(b) Business identification number; and
(c) Employer identification numbers.
(3) Payroll information, including, among other information:
(a) Paychecks; and
(b) Pay stubs.
(4) Cafeteria plan check requests and associated paperwork;
(5) Medical information for any employee or customer, including, but not limited to:
(a) Doctor names and claims;
(b) Insurance claims;
(c) Prescriptions; and
(d) Any related personal medical information.
(6) Other personal information belonging to any customer, employee or contractor, examples of which include:
(a) Date of birth;
(b) Address;
(c) Phone numbers;
(d) Maiden name;
(e) Names; and
(f) Customer number.
(7) (a) Municipal personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. Furthermore, this section should be read in conjunction with the State Public Records Act, being R.C. §§ 149.01 et seq. and the municipality’s open records policy. If an employee is uncertain of the sensitivity of a particular piece of information, he or she should contact his or her supervisor. In the event that the municipality cannot resolve a conflict between this policy and the State Public Records Act, the municipality will contact the State Office of Open Records.
(b) The following log shall be used for public records requests.
Public Records Request Log | |||
Date of Request | Requested By | Records Requested | Date Completed and How Completed |
(B) Hard copy distribution. Each employee and contractor performing work for the municipality will comply with the following policies.
(1) File cabinets, desk drawers, overhead cabinets and any other storage space containing documents with sensitive information will be locked when not in use.
(2) Storage rooms containing documents with sensitive information and record retention areas will be locked at the end of each workday or when unsupervised.
(3) Desks, workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing sensitive information when not in use.
(4) Whiteboards, dry-erase boards, writing tablets and the like in common shared work areas will be erased, removed or shredded when not in use.
(5) When documents containing sensitive information are discarded they will be placed inside a locked shred bin or immediately shredded using a mechanical cross cut or Department of Defense (DOD)-approved shredding device. Locked shred bins are labeled “Confidential paper shredding and recycling”. Municipal records, however, may only be destroyed in accordance with the village’s records retention policy.
(C) Electronic distribution. Each employee and contractor performing work for the municipality will comply with the following policies.
(1) Internally, sensitive information may be transmitted using approved municipal e-mail. All sensitive information must be encrypted when stored in an electronic format.
(2) Any sensitive information sent externally must be encrypted and password protected and only to approved recipients. Additionally, a statement such as this should be included in the e-mail:
“This message may contain confidential and/or proprietary information and is intended for the person/entity to whom it was originally addressed. Any use by others is strictly prohibited.”
(Ord. 32-08, passed - -2008)