170.04 POLICY.
(a) Sensitive Information Policy.
(1) Definition of sensitive information. Sensitive information includes the following items whether stored in electronic or printed format:
A. Credit card information including any of the following:
1. Credit card number (in part or whole);
2. Credit card expiration date;
3. Cardholder name;
4. Cardholder address.
B. Tax identification numbers, including:
1. Social Security number;
2. Business identification number;
3. Employer identification numbers.
C. Payroll information including, among other information:
1. Paychecks;
2. Pay stubs.
D. Cafeteria plan check requests and associated paperwork.
E. Medical information for any employee or customer, including but not limited to:
1. Doctor names and claims;
2. Insurance claims;
3. Prescriptions;
4. Any related personal medical information.
F. Other personal information belonging to any customer, employee or contractor, examples of which include:
1. Date of birth;
2. Address;
3. Phone numbers;
4. Maiden name;
5. Names;
6. Customer number.
G. 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 Ohio Public Records Act and the Municipality's open records policy. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their supervisor.
(2) Hard copy distribution. Each employee performing work for the Municipality and each contractor performing services for the Municipality and handling information for the Municipality that is the subject of this policy will comply with the following policies:
A. File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with sensitive information will be locked when not in use or the room will be locked.
B. Storage rooms containing documents with sensitive information and record retention areas will be locked at the end of each workday or when unsupervised.
C. 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.
D. Whiteboards, dry-erase boards, writing tablets, etc. in common shared work areas will be erased, removed, or shredded when not in use.
E. When documents containing sensitive information are discarded, they will be placed inside a locked shred bin or immediately shredded using a mechanical shredding device. 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.
(3) Electronic distribution. Each employee and contractor performing work for the Municipality that deals with the records that are the subject of this policy will comply with the following policies:
A. Internally, sensitive information may be transmitted using approved municipal e-mail. Sensitive information may be encrypted when sent in an electronic format to entities outside the City.
B. Any sensitive information sent externally may be encrypted and may be 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."
C. The oversight committee will review the possibility of encryption and e-mail security.
(Ord. 27-09. Passed 5-18-09.)
(Ord. 27-09. Passed 5-18-09.)