(a) Sensitive Information Policy.
(1) Definition of sensitive information.
A. Sensitive information includes the following items whether stored in electronic or printed format:
1. Name, social security number, date of birth, official State or government issued drivers license or identification number, alien registration number, government passport number, employer or taxpayer identification number;
2. Unique biometric data, such as fingerprint, voice print, retina or iris image, or other unique physical representation;
3. Unique electronic identification number, address, or routing code; or
4. Telecommunication identifying information or access devise (as defined in 18 U.S.C.,1029(e)).
B. Village 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 Law and the Village's open records policy. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their supervisor. In the event that the Village cannot resolve a conflict between this policy and the Ohio Public Records Law, the Village will contact the Village's legal counsel.
(2) Hard copy distribution. Each employee and contractor performing work for the Village 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.
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. Municipal records, however, may only be destroyed in accordance with the Village's records retention policy.
(3) Electronic distribution.
A. Each employee and contractor performing work for the Village 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 email:
"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. 08-36. Passed 11-3-08.)